January 14, 2025
By: Kevin Levy and Natali Reyes
As of Friday, January 10, 2025, companies are not obligated to make filings under the Corporate Transparency Act (CTA).
In mid-December a Texas court issued a nationwide preliminary injunction with regard to CTA reporting obligations enjoining its enforcement. Since that time, the Texas decision has been reversed (12.23.24) and then re-instated (12.26.24) and there continues to be various appeals and other challenges to the CTA, even pleas being made to the U.S. Supreme Court.
Various courts have set differing schedules for filings and hearings and currently there is no telling if or when the Supreme Court may chime in. Accordingly, things could change at any moment and those potentially subject to the CTA is encouraged to carefully monitor the situation.
The government is still accepting CTA filings on a voluntary basis and some parties have chosen to proceed with filings while others are awaiting the next definitive ruling. Please do not hesitate to reach out to our CTA Team for updates and guidance on applicability and/or compliance.
For additional background, please also review our prior Insights:
- Corporate Transparency Act Updated Filing Deadlines
- Texas Court Issues Preliminary Injunction Blocking Enforcement of the Corporate Transparency Act Nationwide
- Corporate Transparency Act Filing Deadlines Extended for Hurricane Victims
- Corporate Transparency Act Filing Deadline Fast Approaching for Pre-existing Companies
- Corporate Transparency Act and the End of Hiding in the U.S.
Questions?
Contact GrayRobinson Business Law Section Chair Kevin Levy, Attorney Natali Reyes, or a member of the Business Law Section.