Do I Have to Report for the Corporate Transparency Act? – No… For Now
On December 3, 2024, both the Corporate Transparency Act (“CTA”) and its respective implementation regulations (the “Reporting Rule”) imposed by the Financial Crimes Enforcement Network (“FinCen”), were preliminarily enjoined nationwide by the Eastern District Court of Texas in Texas Top Cop Shop, Inc., Et Al., v. Merrick Garland, Et Al., Cause No. 4:24-CV-478.
What This Means for You
Critically, the Texas Court imposed a nationwide preliminary injunction on the CTA and the Reporting Rule. Currently, this means that no reporting companies from any state need to comply with the CTA or the Reporting Rule.
Importantly however, the Court only issued a preliminary injunction. This means that the injunction will continue until the case is finally decided. If the Court’s final decision imposes a permanent injunction, you will not need to report at all. However, if the Court’s final decision does not impose a permanent injunction, you may need to report once the Texas case is finally decided.
Effectively, if you needed to report to FinCEN under the CTA, you no longer need to report right now. While that might change, we will keep you updated with any such developments.
To learn more about Report for the Corporate Transparency Act, please contact Beresford Booth at info@beresfordlaw.com or by phone at (425) 776-4100.
