Corporate Transparency Act and the Beneficial Ownership Information Appeal—Reporting Looming?

As most of us know, the Corporate Transparency Act (CTA) Beneficial Ownership rule (BOI Rule), was nationally enjoined from enforcement on January 7, 2025—the initial reports were due on January 23, 2025. Many companies chose to get ready as injunctions may be only temporary and may be appealed.

In this case, on February 7, 2025, the Government filed a Notice of Appeal and a Motion to Stay [the injunction]. If the Court grants the Motion to Stay the injunction the companies that were required to report—will be required to report again within 30 days. In short, a company’s best bet is to continue to prepare to file as most companies that were required to do so prior to the injunction were nearly ready.