Corporate Transparency Act Enforcement Blocked Again

By Bryce Morrison

On December 26, 2024, a federal appeals court blocked the enforcement of the Corporate Transparency Act (CTA) once again. As a result, reporting companies are currently not required to meet the CTA filing deadlines.

What Happened?

The Corporate Transparency Act requires existing reporting companies formed before January 1, 2024, to file a report with the Treasury Department by December 31, 2024, and newly formed reporting companies to file a report within 90 days of formation. However, the enforcement of these deadlines has been hard to predict:

• December 3, 2024: A federal court issued a nationwide injunction blocking enforcement of the CTA.
• December 23, 2024: A federal appeals court panel lifted the injunction.
• December 26, 2024: The full federal appeals court reinstated the injunction.

What Should You Do?

With the nationwide injunction in place again, reporting companies are currently not required to meet the CTA filing deadlines. However, reporting companies should still be prepared to file the required reports quickly if the injunction is lifted again. When the injunction was previously lifted, the Treasury Department granted a short extension. If the injunction is lifted again, reporting companies are likely to face tight filing timelines.

How is Bernstein Shur Helping Clients Comply with the Corporate Transparency Act?

Our Business Law Practice Group has been closely monitoring the CTA since it was enacted and is ready to assist you. If you have any questions about whether or when you need to file a report, our interdisciplinary business law team is ready to help. Contact your Bernstein Shur attorney or Bryce Morrison at bmorrison@bernsteinshur.com.