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Corporate Transparency Act Reporting Enforcement and January 1 Deadline Blocked Nationwide by Texas Court

On Tuesday, December 3, 2024, a federal District Court in the Eastern District of Texas issued a national preliminary injunction that enjoined the federal government from enforcing the Corporate Transparency Act (CTA) beneficial ownership interest reporting requirements, including the January 1, 2025 deadline, on companies formed prior to January 1, 2024:  Texas Top Cop Shop, Inc. v. Garland, E.D. Texas, No. 4:24-CV-00478, December 3, 2024. 

The issuance of national preliminary injunctions is controversial, a fact acknowledged by the Texas court in its opinion.  We expect the decision to be reviewed quickly by the U.S. Court of Appeals for the Fifth Circuit and, depending on how that appellate court rules, possibly by the U.S. Supreme Court. At the time of this update, the United States Treasury Department has not issued a statement about the Texas decision.  We expect additional legal developments on this subject in the very near future.  We will continue to update our clients on this matter if they have signed up to receive CTA updates here.

Important Notice Regarding the Corporate Transparency Act Filing Requirements (Updated 3/4/2024)

UPDATED 3/04/2024

On March 1, 2024, a lower Alabama federal court held that the Corporate Transparency Act, which requires certain businesses to file a BOI Report with FinCEN that includes information about their beneficial owners, is unconstitutional. Importantly, this ruling DOES NOT affect the legal obligation of entities formed in California, Nevada, or Delaware (among other states) to file their BOI Report within the timeframes specified in the chart below at this time.  We are monitoring the development of this and similar court actions across the nation and will continue to provide information about them to those who have indicated a desire to receive this information from us.