Late on December 26, 2024, a Fifth Circuit panel ordered the order reinstated. The timing of any oral arguments or other court decisions is uncertain. Voluntary submission is possible. In any case, we do not expect FinCEN to reintroduce the 12/31/2024 deadline, as they previously announced the January 13, 2025 grace period.
As such, voluntary filing is available and may be the best route given the back and forth between government and the legal system. Because the order is in effect, FinCEN cannot enforce the CTA.
Visit: Reporting of beneficial ownership information | FinCEN.gov
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