December 31, 2024 Filing Deadline for the Corporate Transparency Act Suspended

On November 28, 2023 and November 22, 2024, our office notified you that you may have reporting obligations under the Corporate Transparency Act (“CTA”).

Earlier this week, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against the enforcement of the CTA on the basis that the CTA and its reporting requirements are likely unconstitutional (See Texas Top Cop Shop, Inc. et. al v. Merrick Garland (Case No. 4:24-cv-00478 December 3, 2024).

The preliminary injunction is expected to remain in place until further ordered by the Court. The Department of Justice is likely to appeal the decision on an expedited basis.

What Does This Mean For You?

Reporting companies who otherwise would have had a legal obligation to file a beneficial ownership report, whether on formation or those initial reports due December 31, 2024, are temporarily relieved from filing such beneficial ownership reports.

What Should You Do Next?

Subsequent appeals and rulings may affirm or overturn the preliminary injunction. It is also unclear what actions the new administration may take.

If the preliminary injunction is overturned, it is not clear how long reporting companies will have to file their beneficial ownership reports.

Voluntarily Reporting

You may still complete the beneficial ownership report prior to December 31, 2024; however, at this time, you have no legal obligation to complete such report.