On December 3, 2024, a Federal judge in Texas issued a nationwide preliminary injunction blocking enforcement of the Corporate Transparency Act’s (“CTA”) Reporting Rule and staying the compliance deadline. The government likely will appeal the injunction but there is no way to predict the timing or outcome of any appeal.
If the injunction is reversed, the CTA filing requirements would then be reinstated. While the Appeals court likely would then extend for some period of time to permit companies to comply, there is no way to predict whether or how much time would be allowed.
Companies that have already filed to meet the CTA requirements do not need to take any further action at this time.
Companies that have not yet filed can choose not to file pending the outcome of any appeal. That said, businesses may nevertheless decide it is safer to file the CTA reports to avoid a sudden or potentially unreasonable time limit if the injunction is reversed.
