Decision comes just ahead of the January 1, 2025 CTA filing deadline.

On December 3, 2024, the U.S. District Court for the Eastern District of Texas, in Texas Top Cop Shop, Inc. et al. vs. V. Merrick Garland, issued a nationwide preliminary injunction prohibiting the enforcement of the Corporate Transparency Act (CTA), which requires certain legal entities formed before January 1, 2024 to file a Beneficial Ownership Information (BOI) report with the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) by January 1, 2025. The Court determined that the CTA and Reporting Rule are likely unconstitutional and that “reporting companies need not comply with the CTA’s January 1, 2025, BOI reporting deadline pending further order of the Court.”  (Emphasis added.)  This ruling applies to all reporting companies under the CTA – not just the plaintiffs in this case.

What to Expect

This ruling only temporarily pauses enforcement of the CTA nationwide. Therefore, we expect further developments and will continue to closely monitor the CTA and provide further guidance and updates as necessary.

You can find a copy of the order here.

UB Greensfelder attorneys are here to assist and can answer questions you have about the CTA and this recent decision. For any questions or further information, please contact Patrick Sweeney.

The information provided in this client alert speaks only to the information and guidance we have available as of the date of publication and is subject to change. This legal update was created by UB Greensfelder LLP, and is not intended as a substitute for professional legal advice. Receipt of this client alert, by itself, does not create an attorney-client relationship. For any questions, or for further information, please contact your UB Greensfelder attorney.