We are writing with an important update on the Corporate Transparency Act (CTA). On December 3rd, 2024, the U.S. District Court for the Eastern District of Texas granted a preliminary injunction that temporarily halts the enforcement of the CTA nationwide and suspends the reporting requirements, which were to be effective on January 1, 2025. This decision means that entities subject to the CTA are not required to file beneficial ownership reports with FinCEN at this time and can defer any reporting obligations. This is not a permanent injunction and the case is ongoing. This means that an appellate court may overturn the injunction. The US government has 60 days to file a notice of appeal and we anticipate the Treasury Department will issue a statement regarding the injunction.
We are closely monitoring CTA developments and will be prepared to resume compliance activities and meet any reporting requirements if the injunction is lifted as the case progresses. Please don’t hesitate to reach out to Shaheen Sheik-Sadhal (shaheen@mitzelgroup.com), of our Corporate Team, or Krista L. Mitzel (kmitzel@mitzelgroup.com with any questions or for additional support. We are committed to keeping you informed and prepared for any changes that may arise in this ongoing legal matter.
