Corporate Transparency Act Update

UPDATE: On December 23, the Fifth Circuit Court of Appeals lifted the injunction that prohibited the enforcement of the Corporate Transparency Act.  Therefore, companies required to make a filing under the CTA must do so by January 13, 2024.  We encourage clients who haven’t already done so to consult with us to determine their next steps.  ‍

On December 3rd, the United Stated District Court for the Eastern District of Texas held on a preliminary basis that the Corporate Transparency Act is likely unconstitutional and issued a preliminary injunction that prohibits enforcement of the CTA for the time being. As such, so long as the preliminary injunction remains in effect, no reporting company is required to file a report under the CTA. The future of the preliminary injunction is unclear, as is the timetable for reporting that will go into effect if it is lifted. Given the ongoing uncertainty, clients who were required to report should consult with us to determine their best action until these issues are resolved.