Important Update: Corporate Transparency Act (CTA) Developments

Today, we’d like to share some important news regarding recent developments surrounding the Corporate Transparency Act (CTA):

• Court Ruling: On December 3, in Texas Top Cop Shop, Inc., et al. v. Garland, et al. (U.S. District Court for the Eastern District of Texas), a preliminary injunction was issued. This decision temporarily blocks the U.S. Department of Treasury from enforcing the CTA’s beneficial ownership information (BOI) reporting requirements.
• FinCEN Guidance: In response, FinCEN issued updated guidance over the weekend. It states:

“In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.”

Amid this uncertainty, reporting companies should continue preparing for potential BOI reporting requirements in case the injunction is lifted. Additionally, it is essential to note that state-level BOI reporting obligations remain unaffected by this federal ruling. Please contact us if you have any questions on how this decision may impact your filing requirements.