- with readers working within the Aerospace & Defence, Business & Consumer Services and Retail & Leisure industries
As previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction on the enforcement of the Corporate Transparency Act (the "CTA") and its reporting obligations. On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the preliminary injunction. Following the Fifth Circuit's stay, the Financial Crimes Enforcement Network ("FinCEN") released a statement granting an extension to the CTA year-end reporting deadline to January 13, 2025.
However, on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated their stay of the preliminary injunction in light of the expedited ruling expected on the merits of the preliminary injunction.
FinCEN has not yet issued a statement but it is anticipated that they will comply with the injunction as they did last time while allowing reporting companies to voluntarily submit reports. In light of ongoing uncertainty, KMK recommends that entities continue preparing their CTA reports and be prepared to file on short notice if the preliminary injunction is one again stayed or overturned.
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