| Now that the end of year holidays are over, we wanted to take a moment to update you on the current state of the beneficial ownership reporting requirements of the Corporate Transparency Act (“CTA”). As of today’s date, the reporting requirements remain paused. As discussed in our previous client alert on this topic, on December 23, 2024, a motions panel of the U.S. Court of Appeals for the Fifth Circuit granted a stay of the district court’s preliminary injunction entered in the case of Texas Top Cop Shop v. Garland, reviving the requirement for reporting companies to file beneficial ownership information under the CTA. However, on December 26, 2024, a separate merits panel of the Fifth Circuit issued an order vacating the Court’s stay of the preliminary injunction. As a result, the January 13, 2025 deadlines published by FinCEN in response to the Fifth Circuit’s initial stay are currently not in effect and, therefore, reporting companies are not required to file beneficial ownership information with FinCEN at this time. This situation is dynamic, and, as of now, it is unclear if the beneficial owner filing requirement will survive appellate review. However, FinCEN has suggested that beneficial owners may still comply with the CTA by voluntarily filing their beneficial ownership information. If you would like to move forward with your beneficial ownership reports, please reach out to us to discuss. If Sadis was previously assisting you with your CTA reporting we will be in touch shortly. We will continue to monitor this situation and update our clients on their CTA obligations in a timely manner. If you have any questions about your CTA filing obligations, please feel free to contact David Fitzgerald at 212-573-8428 or dfitzgerald@sadis.com, Mark Strefling at 212-573-8159 or mstrefling@sadis.com, or Cameron Posillico at 212-573-8151 or cposillico@sadis.com. |