FWW Alert: The CTA Roller Coaster Continues

1/6/2025

Just a few days ago we sent a client alert explaining that on December 23, 2024, a prior injunction against enforcement of the federal Corporate Transparency Act (CTA) had been lifted, thereby pushing many clients (and us) on a scramble to again prepare for filings in order to avoid onerous penalties under the law. This was the lump of coal in our stockings from your friends at the federal government and it brings to mind the classic Reagan warning in 1986 about the nine most terrifying words in the English language – "I'm from the government and I'm here to help."

Well, to celebrate the New Year we have good news on the CTA front again. Capping off a tumultuous month for the CTA, late on December 26, 2024, the merits panel of the U.S. Court of Appeals for the Fifth Circuit (Fifth Circuit) reinstated the nationwide preliminary injunction blocking the Financial Crimes Enforcement Network (FinCEN) from enforcing the CTA.  As a result, reporting companies under the CTA are, once again, not required to file their beneficial ownership information with FinCEN while the preliminary injunction remains in effect. As several have stated, you can't make this stuff up!

Click here to view the full alert.