While most of us were indulging in holiday cheer by watching How the Grinch Stole Christmas, the United States Court of Appeals for the Fifth Circuit kept itself busy with the Corporate Transparency Act  (CTA), delivering holiday drama in the form of contradictory rulings that left business owners and advisors scrambling.

First, on December 23, 2024, the Court delivered a gift no one asked for: it lifted the nationwide preliminary injunction on the CTA, bringing the reporting requirements back to life and setting a tight new filing deadline of January 13, 2025.

On December 26, a different panel of Fifth Circuit judges reversed the previous order, citing the need “to preserve the constitutional status quo while the merits panel considers the parties’ weighty substantive arguments.”

On December 28, FinCEN updated its website with an Alert confirming that businesses are currently off the hook for filing their BOI reports and won’t face penalties while the order remains in effect. FinCEN also reminded everyone that they could still voluntarily file their reports. After all, who could resist a little extra paperwork during the holiday season?

An oral argument on the CTA’s constitutionality is scheduled for March 25, 2025. While the compliance obligations are on hold, those business owners who decide to wait should be prepared to file at a moment’s notice. Remember the Grinch – “It [may come] without ribbons, it [may come] without tags. It [may come] without packages, boxes, or bags.”