On January 23, 2025, it appeared that the Supreme Court had given the green light to FinCEN to resume enforcement of the Corporate Transparency Act (CTA) and its beneficial ownership information reporting requirements after granting FinCEN’s motion to stay a nationwide injunction by a federal judge in Texas in the Texas Top Cop Shop case. FinCEN indicated that due to a separate nationwide injunction by a different federal judge in Texas (in the Smith case), reporting companies are still not currently required to file beneficial ownership information.
In short, the CTA is still parked at a red light and is not being enforced. Voluntary reporting remains available, and we will continue to monitor for developments.
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