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ARTICLE · 06 DECEMBER 2024

Corporate Transparency Act Reporting

Holland & Knight
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The U.S. District Court for the Eastern District of Texas on Dec. 3, 2024, issued a nationwide preliminary injunction suspending (temporarily) the government's enforcement...

United StatesCorporate/Commercial Law
Jonathan N. Halpern
Jonathan N. Halpern
Alan Winston Granwell
Alan Winston Granwell
Gabriel Caballero Jr.
Gabriel Caballero Jr.
Michael C. Titens
Michael C. Titens
Louis Conti
Louis Conti
Melissa Pereira
Melissa Pereira
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Highlights

  • The U.S. District Court for the Eastern District of Texas on Dec. 3, 2024, issued a nationwide preliminary injunction suspending (temporarily) the government's enforcement of the Corporate Transparency Act (CTA) and its Implementing Regulations. This is the first federal district court in the country to issue a nationwide injunction.
  • It is expected that the government may seek an expedited appeal of the decision and request a stay of the order of the federal district court.
  • As the ultimate outcome of this decision is uncertain at this time, Reporting Companies that have not filed to date would be well advised to continue to gather the requisite information for filing and be prepared to file in anticipation of an appeals court granting a stay of the district court's order or otherwise limiting the application of the nationwide temporary injunction and enjoinment of the Beneficial Ownership Information (BOI) Reporting Rule.

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