Corporate Transparency Act Compliance Client Alert: Fifth Circuit Reinstates National Injunction – CTA Optional Again

Dec 30, 2024

The firm has previously notified our clients and network about an obligation to make certain filings under the Corporate Transparency Act (CTA) that became effective at the beginning of 2024.

It provided deadlines to file Beneficial Ownership Information (BOI) for many companies by December 31 of this year, and in some cases required earlier deadlines.

As you may know, a number of lawsuits were filed in various federal courts around the country aimed at declaring the CTA unconstitutional or otherwise limiting its enforcement. In early December, one district court ordered a nationwide injunction against enforcement of the CTA. This order went to an appellate court that, this past Monday, overturned the injunction, and then on Wednesday reversed itself and reinstated the nationwide injunction.

As a result of all these competing decisions, the current status, as of the end of 2024, is that the government may not currently enforce the CTA rules. Therefore, as long as the current injunction remains in place, there is no obligation for any of our clients to file BOI reports, although such reports may still be filed voluntarily.

There will clearly be additional decisions from various courts, and whether the CTA is ultimately enforceable will probably be decided by the U.S. Supreme Court in the new year. We will provide updates as they occur.

If you have any questions, please don’t hesitate to contact [email protected].

About Greenspoon Marder

Greenspoon Marder LLP is a full-service law firm with over 225 attorneys and more than 20 office locations across the United States. With operations from Miami to New York and from Denver to Los Angeles, our firm attracts some of the nation’s top talent in key markets and innovation hubs. Our core practice areas include Real Estate, Litigation, and Transactional Services, complemented by the capabilities of a full-service firm. Greenspoon Marder has maintained a spot on The American Lawyer’s Am Law 200 as one of the top law firms in the U.S. since 2015, and our goal is to provide exceptional client service by developing a thorough understanding of each client’s business needs and objectives in order to provide strategic, cost-effective solutions.

MEDIA CONTACT

Natalie Villanueva, Director of Marketing
954.333.4308 | [email protected]

This Greenspoon Marder LLP Client Alert is issued for informational purposes only and is not intended to be construed or used as general legal advice nor a solicitation of any type. Please contact the author(s) or your Greenspoon Marder LLP contact if you have any questions regarding the currency of this information. The hiring of a lawyer is an important decision. Before you decide, ask for written information about the lawyer’s legal qualifications and experience.

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Corporate Transparency Act Compliance Client Alert: Fifth Circuit Reinstates National Injunction – CTA Optional Again

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