Corporate Transparency Act Update

UPDATE 2/19/2025: On January 18 the U.S. District Court for the Eastern District of Texas lifted the injunction and placed the reporting requirements of the Corporate Transparency Act (CTA) back in effect.  Therefore, companies that were in existence before January 1, 2024 must file a Beneficial Ownership Information report before March 21, 2025.  This deadline may be extended by the Financial Crimes Enforcement Network.

UPDATE 12/30/2024: On December 26, the Fifth Circuit Court of Appeals reversed course and reinstated the CTA injunction, which again pauses all year-end filing obligations. As has become standard fare in the CTA litigation, the reinstated injunction is of uncertain duration, and the ultimate fate of the CTA remains unclear. We will continue to provide guidance as it becomes available.

UPDATE 12/26/2024: 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.