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Corporate Transparency Act Compliance Still on Hold
The U.S. Court of Appeals for the Fifth Circuit made two rulings on the Corporate Transparency Act (CTA) within a week. On December 23 it lifted the U.S. District Court for the Eastern District of Texas's preliminary injunction, requiring reinstatement of reporting obligations under the CTA for those entities required to comply. However on December 26, the Court vacated its decision to lift the preliminary injunction. This means that again, at this time, no entity is required to comply with the CTA.
Eastman & Smith associate Lauren A. Lowe discussed the Court’s recent rulings with the Toledo Blade. Her comments can be viewed in the December 27 article.
Given the flurry of activity regarding the CTA and its enforcement, if you are required to comply with the reporting obligations of the CTA, be prepared to file in the event this preliminary injunction is again lifted. Alternatively, you may still choose to file a beneficial ownership information report proactively, but it is not required at this time.
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Disclaimer: This alert has been prepared by Eastman & Smith Ltd. for informational purposes only and should not be considered legal advice. This information is not intended to create, and receipt of it does not constitute, an attorney/client relationship.