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Yesterday, a federal district court in Texas issued a nationwide preliminary injunction barring enforcement of the Corporate Transparency Act's ("CTA") reporting requirements. This applies to all reporting companies that were facing a deadline to report on or before January 1, 2025. We recommend that companies with CTA reporting obligations weigh whether to voluntarily comply with the CTA during the period of the preliminary injunction. In any event, reporting companies should be prepared to comply if there is an appeal and the Fifth Circuit terminates the preliminary injunction.
We will be monitoring this case and other pending cases, such as in the Western District of Michigan and Eastern District of Virginia, as well as guidance that may come from FinCEN relative to this preliminary injunction or those companies who have already filed.
UPDATE: Please see our most recent CTA alert issued on December 24, 2024 here.
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