Client Alert: Corporate Transparency Act Filings Remain Voluntary

By Zachary M. Chupak and Julie K. O’Neill • January 27, 2025

This Client Alert is an update to our last alert published on January 23, 2025.

On January 23, 2025, the Supreme Court stayed the nationwide injunction issued by the Fifth Circuit, thus purportedly allowing FinCEN to enforce the beneficial ownership information filing requirements of the Corporate Transparency Act.

However, a separate nationwide order issued by a different federal judge in Texas is still in place. This means that for now, compliance with the beneficial ownership information filing requirements remains voluntary.

Employers and companies with questions about how to comply with the CTA should consult their Bowditch attorney. We will assume you are handling these matters on your own unless you request assistance from your Bowditch attorney in writing.

Categorized: Client Alerts, Publications

Tagged In: business owners, FinCen, Beneficial Ownership Information, CTA

About the Authors

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Partner

Julie K. O’Neill

Julie O’Neill focuses her practice on business, corporate and securities law, and counseling individuals and entities at all stages of the corporate life cycle on a wide variety of sophisticated transactions in the U.S., Canada, and abroad. Julie regularly handles:

Entity selection and formation
Private placements including angel and venture capital equity financings
Limited liability company operating agreements and shareholders’ agreements
Mergers and acquisitions
Recapitalizations
Private equity fund formation
Secured transactions
Employment issues and partnership disputes
Licensing arrangements and general contract matters
Trademark and copyright registrations

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Associate

Zachary M. Chupak

Zachary Chupak is an Associate in the Estate, Financial & Tax Planning Practice Area. He assists high-net worth individuals and families in need of asset protection, business succession planning and gift and estate tax strategies. Multi-generational and blended families seek Zach’s assistance with estate planning, estate administration, probate and tax litigation, and family office needs. 

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