Corporate Transparency Act Update: Supreme Court Stays Nationwide Injunction – CTA Reporting Obligations Back in Effect

Today, the United States Supreme Court reinstated the Corporate Transparency Act (the “CTA”) and allowed its reporting obligations to go into effect pending a challenge to the law’s merits in the U.S. Court of Appeals for the Fifth Circuit.

Acting on an emergency application, the Supreme Court stayed the nationwide injunction blocking enforcement of the CTA that was originally issued in December 2024 by the U.S. District Court for the Eastern District of Texas. The Court’s order, which gave no reasons for the stay, can be found here.

Given the CTA’s ongoing legal challenges, the Financial Crimes Enforcement Network (“FinCEN”) had previously granted an extension to the CTA year-end reporting deadline to January 13, 2025. While FinCEN has not yet commented on today’s ruling, we anticipate that they will grant an additional extension for companies to comply with the CTA’s reporting obligations.

KMK recommends that entities resume preparations of their CTA reports and be prepared to submit filings when FinCEN provides updated guidance on the CTA reporting deadline.

KMK Law articles and blog posts are intended to bring attention to developments in the law and are not intended as legal advice for any particular client or any particular situation. The laws/regulations and interpretations thereof are evolving and subject to change. Although we will attempt to update articles/blog posts for material changes, the article/post may not reflect changes in laws/regulations or guidance issued after the date the article/post was published. Please consult with counsel of your choice regarding any specific questions you may have.

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