Published December 10, 2024
On December 3, 2024, a Texas federal district court issued a preliminary injunction which blocks enforcement of the Corporate Transparency Act (“CTA”) nationwide.
In Texas Top Cop Shop, Inc. v. Garland, E.D. Tex., No. 4:24-cv-00478, Judge Mazzant temporarily enjoined the government from enforcing the requirements of the CTA, which include the requirement that most private U.S. companies, including corporations, limited liability companies (LLCs), and other forms of business entities, file a Beneficial Owner Report (“BOI” report) with the Financial Crimes Enforcement Network (“FinCEN”). This injunction comes just weeks before the January 1, 2025 deadline.
As a result of this recent development, reporting companies who have not yet filed a BOI report may choose to delay their filings until further guidance comes from the Court.
The online reporting website for FinCEN remains active and reporting companies may still file a BOI report using the E-filing system at https://www.fincen.gov/boi.
Penalties for noncompliance with the CTA are steep, so reporting companies should keep abreast of legal developments and prepare for compliance if they choose to delay.
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