On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., concluding that the Corporate Transparency Act (“CTA”) exceeds the U.S. Constitution’s limits on Congress’ power. The court ultimately blocked the U.S. Department of Treasury and FinCEN from enforcing the CTA and its beneficial ownership information reporting requirements. This decision applies to all reporting companies nationwide.
The court blocked both the CTA’s statutory provision (31 U.S.C. § 5336) and its implementing regulation (31 C.F.R. § 1010.380). The result of this Texas decision is that reporting companies nationwide are not legally required to comply with the BOI reporting requirements, including the January 1, 2025 deadline, until further court order. In the event you are unsure whether to still comply, please do not hesitate to reach out to one of the attorneys on WTJ’s transactional team.