On Dec. 3, 2024, Judge Amos L. Mazzant of the US District Court for the Eastern District of Texas issued a nationwide preliminary injunction prohibiting the government from enforcing the Corporate Transparency Act (“CTA”) and its implementing regulation (31 C.F.R. §1010.380 (“Reporting Rule”)) and enjoining enforcement of the filing deadlines thereunder. The CTA, which was enacted on Jan. 1, 2021, and the Reporting Rule require certain legal entities (known as “Reporting Companies”) to file a beneficial ownership information report (“BOI Report”) with the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”). [1] This ruling is noteworthy in light of the upcoming reporting deadlines under the CTA and Reporting Rule, which require that Reporting Companies formed or registered to do business in the US: (1) before Jan. 1, 2024, are required to file their initial BOI Report by Jan. 1, 2025; or (2) in 2024 are required to file their initial BOI Report within 90 days of formation or first registration.
Read MoreJuly 11, 2026