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UPDATE – On Dec. 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated the ruling of its own motions panel, and the nationwide injunction enjoining enforcement of the CTA is once again in effect. The CTA is not currently in effect. That said, given the inconsistency we have seen relating to the various injunctions and short extensions granted by FinCEN, we recommend our clients continue preparations to comply with the CTA. On Dec.
On December 2, 2024, the IRS published final regulations under Code1 Sections 704 and 752 (pursuant to authority set forth in Code Section 7805(a)) relating to a partner's share of recourse partnership liabilities, largely adopting the proposed regulations issued over a decade ago.
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