An order from the U.S. District Court for the Eastern District of Texas granted a nationwide preliminary injunction of the Corporate Transparency Act (“CTA”) and enforcement of the associated rule requiring the submission of beneficial ownership reports (“BOI reports”) to the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”). The same order stayed the January 1, 2025 deadline for filing BOI reports. The Court’s order is a preliminary injunction only and not a final decision. Enforcement could resume if the Court’s order is overturned on appeal or because of further orders by the trial court.

Tuggle Duggins will not be submitting BOI reports until further notice. Nevertheless, BOI reports are still being accepted on a voluntary basis. If you are currently gathering the information needed to file a BOI report, we suggest you continue that process in case the injunction is lifted or modified.

The Department of Justice has appealed the order. We will continue to keep you updated as to your obligations under the CTA as developments occur. Please note that while North Carolina does not impose state-level CTA reporting obligations, there are other states that do impose reporting requirements. These state-level obligations remain unaffected by this ruling. Should you have any questions about this injunction, please contact Madison Boyer at mboyer@tuggleduggins.com.

© 2024 Tuggle Duggins P.A. All Rights Reserved. The purpose of this bulletin is to provide a general summary of significant legal developments. It is not intended to constitute legal advice or a recommended course of action in any given situation. It is not intended to be, and should not be, relied upon by the recipient in making decisions of a legal nature. Moreover, information contained in this bulletin may have changed subsequent to its publication. This bulletin does not create an attorney-client relationship between Tuggle Duggins P.A. and the recipient. Therefore, please consult legal counsel before making any decisions or taking any action concerning the issues discussed herein.