On December 17, 2024, U.S. District Judge Amos Mazzant refused the federal government’s request to stay—a legal pause—the nationwide preliminary injunction that had stopped enforcement of the Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) Reporting Rule. The ruling preserved the injunction while the case continued. It is historical litigation context, not a current filing directive: FinCEN’s final rule effective August 14, 2026, now exempts U.S.-formed companies and U.S. persons from the described BOI duties while retaining reporting for certain foreign-formed entities registered to do business in the United States.
What Judge Mazzant decided on December 17, 2024
Judge Mazzant denied the government’s motion to stay his earlier preliminary injunction. Forbes reported the underlying nationwide injunction on December 3, 2024, and the stay denial on December 17. A stay would have temporarily lifted the injunction during an appeal, allowing CTA and BOI-reporting enforcement to resume while the court process continued. By refusing the stay, Mazzant left the injunction in place at that stage of the case.
The decision concerned enforcement during litigation; it was not a final ruling resolving every issue in the lawsuit.
Why the government’s stay request failed
Forbes reported that Mazzant applied the traditional four-factor test courts use when deciding whether to pause an order pending appeal.
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Likelihood of success on the merits
The government had to show a sufficient likelihood that it would prevail on appeal. Mazzant concluded it had not met that burden. Forbes reproduced this passage from his order: “As discussed in detail by the Court’s Order enjoining the CTA and Reporting Rule, both are likely unconstitutional; Plaintiffs have thus carried their burden to show a substantial likelihood of success on the merits. The Government has not.”
Irreparable injury to the applicant
The court also considered whether the party seeking the stay would suffer irreparable harm without one. This factor is part of the required analysis, but the reported decision did not identify it as enough to overcome the government’s failure to establish the necessary likelihood of success.
Injury to other interested parties
A stay analysis weighs the harm a pause could cause to opposing parties and other affected interests. The injunction’s nationwide scope meant that lifting it would have changed the compliance position for covered entities across the country while the constitutional challenge proceeded.
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The public interest
Courts separately consider the public interest. After weighing the factors, Mazzant declined to pause his injunction. Forbes reported his conclusion as: “the Court will not stay its Order enjoining enforcement of the CTA and Reporting Rule.”
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What the nationwide preliminary injunction covered
The December 3, 2024 order was reported as a nationwide preliminary injunction against the CTA and its BOI Reporting Rule. In practical terms, it blocked the government from enforcing the reporting regime covered by that order while the case proceeded. “Preliminary” means the order was issued before a final merits judgment; “nationwide” describes its geographic reach, not a determination that every entity would ultimately be subject to the statute.
The December 17 ruling did not create a new reporting exemption. It refused to suspend the existing injunction during the appeal.
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How the 2024 litigation differs from today’s BOI rules
FinCEN’s current BOI page says a final rule issued August 11, 2026, and effective August 14, 2026, changed the reporting framework. That agency rule and the 2024 court injunction are different legal mechanisms and should not be treated as interchangeable.
| Issue | December 2024 litigation posture | FinCEN framework effective August 14, 2026 |
|---|---|---|
| What changed | Mazzant refused to stay a nationwide preliminary injunction. | A final FinCEN rule established permanent exemptions described on the agency’s current BOI page. |
| Legal mechanism | Federal court order issued during constitutional litigation. | Agency rule governing the reporting framework. |
| U.S.-formed companies | The injunction blocked enforcement covered by the order at that time. | Exempt under FinCEN’s current summary. |
| U.S. persons | The stay denial concerned enforcement of the challenged regime. | Exempt under FinCEN’s current summary. |
| Certain foreign-formed entities registered in the United States | Covered by the litigation’s broader enforcement dispute as described in contemporaneous reporting. | Remain within the reporting framework, subject to applicable exemptions. |
Who may still have a reporting obligation under the current rule
FinCEN’s August 2026 summary says only certain foreign companies registered to do business in the United States must report under the remaining framework. The exact entity’s status and any applicable exemption matter; “foreign-formed” alone does not answer every compliance question.
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U.S.-formed companies
FinCEN says U.S.-formed companies are exempt under the final rule effective August 14, 2026. They should not use the old 2024 deadlines or injunction coverage as a substitute for checking the current rule.
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U.S. persons and U.S.-person beneficial owners
FinCEN says U.S. persons are exempt from the stated BOI duties. For a foreign-formed reporting company that remains covered, the agency’s summary says it does not need to report BOI for U.S.-person beneficial owners or company applicants.
FinCEN identifiers and previously submitted information
FinCEN also says U.S. persons who have a FinCEN ID are not required to update or correct information previously submitted. That statement addresses the agency’s current rule; it does not revive a general filing duty for U.S.-formed companies.
What this historical ruling means for readers
- The headline refers to a specific event: Mazzant denied the government’s stay motion on December 17, 2024.
- The order he declined to pause was the nationwide preliminary injunction reported on December 3, 2024.
- Forbes reported that the judge used the standard four stay factors and found the government had not shown the required likelihood of success.
- Current obligations must be determined under FinCEN’s final rule effective August 14, 2026, rather than by relying on 2024 injunction coverage or superseded filing deadlines.
- A foreign-formed entity registered to do business in the United States should check whether it falls within FinCEN’s remaining reporting category and whether an exemption applies.
Forbes’ contemporaneous account was published December 18, 2024, and updated April 2, 2025. FinCEN’s current BOI page carries the August 11, 2026 rule alert and August 14, 2026 effective date. The sources summarized here do not establish the complete later appellate or docket history of the case, so the December 2024 stay denial should be read as a snapshot of the litigation at that time.
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