Corporate Transparency Act Enforcement Enjoined Again

An order issued on December 26, 2024, by the U.S. Court of Appeals for the Fifth Circuit has reinstated the injunction imposed by the United States District Court for the Eastern District of Texas, which enjoins the Corporate Transparency Act (the “CTA”) and enforcement of the reporting rules under the CTA and stays the January 1, 2025, compliance deadline. As a result, reporting companies are currently not required to submit beneficial ownership information reports under the CTA.

With the current uncertainty regarding the fate of the CTA, clients should continue to monitor CTA developments at this time and should be prepared to file the reports required by the CTA if the injunction is lifted. Although not legally required while the preliminary injunction remains in effect, clients may also consider making a voluntary filing.

Please reach out to AGG Corporate & Finance co-chair Sherman Cohen or your AGG relationship partner with any questions.