The Corporate Transparency Act (CTA) requires most U.S. business entities, including most corporate brokerages, to report stakeholder information to the Treasury Department. In early December, a lower federal court in Texas ruled the CTA unconstitutional and issued a preliminary injunction blocking enforcement of the Beneficial Owner Information (BOI) reporting requirements.  

On December 23, 2024, the 5th Circuit Court of Appeals lifted the preliminary injunction. Following the ruling, the Financial Crimes Enforcement Network (FinCEN) reinstated the BOI reporting requirements with an extension. On December 26, 2024, the 5th Circuit Court of Appeals issued a new order reinstating the preliminary injunction while it considers the substantive arguments on appeal. The reporting requirements would have applied to most corporate brokerages, including agent owned corporations used primarily for tax purposes. C.A.R. will update this page with new developments as they become available.

See C.A.R.’s Quick Guide, “Corporate Transparency Act and Beneficial Ownership Information Reporting” for further information.

FinCEN also has posted frequently asked questions about the CTA and BOI reporting requirements.

December 27, 2024