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Today, the United States Supreme Court reinstated the Corporate Transparency Act (the "CTA") and allowed its reporting obligations to go into effect pending a challenge to the law's merits in the U.S. Court of Appeals.
Today, the United States Supreme Court reinstated the Corporate
Transparency Act (the "CTA") and allowed its reporting
obligations to go into effect pending a challenge to the law's
merits in the U.S. Court of Appeals for the Fifth Circuit.
Acting on an emergency application, the Supreme Court stayed the
nationwide injunction blocking enforcement of the CTA that was
originally issued in December 2024 by the U.S. District Court for
the Eastern District of Texas. The Court's order, which gave no
reasons for the stay, can be found here.
Given the CTA's ongoing legal challenges, the Financial
Crimes Enforcement Network ("FinCEN") had previously
granted an extension to the CTA year-end reporting deadline to
January 13, 2025. While FinCEN has not yet commented on today's
ruling, we anticipate that they will grant an additional extension
for companies to comply with the CTA's reporting
obligations.
KMK recommends that entities resume preparations of their CTA
reports and be prepared to submit filings when FinCEN provides
updated guidance on the CTA reporting deadline.
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about your specific circumstances.