Corporate Transparency Act Update: Reporting Obligations Remain Voluntary Despite Recent U.S. Supreme Court Order
By: John Fuchs, Rachel Sterbenz, and Tate Thompson
As we initially reported, the Corporate Transparency Act (“CTA”) took effect on January 1, 2024, requiring Reporting Companies (as defined by the CTA) to file beneficial ownership information reports (“BOIRs”) with the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”). Throughout 2024, multiple plaintiffs challenged the constitutionality and enforceability of the CTA in federal courts across the nation. On December 3, 2024, in Texas Top Cop Shop, the U.S. District Court for the Eastern District of Texas declared the CTA “likely unconstitutional” and issued a nationwide preliminary injunction halting its enforcement.
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