CTA injunction reinstated: continuing uncertainty

Article | January 03, 2025

The nationwide injunction on the reporting requirements under the Corporate Transparency Act (CTA) has been reinstated, pausing enforcement yet again. This development follows the Fifth Circuit Court’s decision to block the Act temporarily while constitutional challenges proceed. For businesses, this legal back-and-forth highlights the uncertainty surrounding the CTA and its requirements.

If there’s one takeaway from this legal whiplash, it’s that entities should prepare their beneficial ownership information (BOI) regardless of the current enforcement pause. With the CTA’s ultimate fate unresolved, having this information ready will position businesses to adapt quickly to future developments and avoid potential compliance headaches.

What Beneficial Ownership Information (BOI) should you gather?

To prepare for potential future compliance, entities should collect the following information for each beneficial owner:

• The individual’s name as shown on legal documents.

• Their date of birth.

• A current residential or business address.

• A unique identifying number, such as a driver’s license or passport number, along with an image of the document. 

Having this information on hand ensures that your entity is ready to comply with CTA reporting requirements should enforcement resume.

It's important to note that you can still voluntarily submit beneficial ownership information reports now while the issue makes its way through the court system.

Stay prepared and informed

Given the ongoing legal developments, it’s crucial for reporting companies and beneficial owners to stay connected with their CPA or compliance advisor. Regular communication ensures you are updated with any changes to the CTA’s status and prepared to act quickly if the reporting requirements are reinstated.

Please contact our office with any questions.