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Corporate Transparency Act Enforcement Resumes Following Legal Reversal

The reinstatement of the Corporate Transparency Act (CTA) enforcement signals a critical compliance deadline for businesses across the U.S.

The Ruling Overview

On December 16, 2025, a Texas federal court lifted a nationwide injunction that had halted the enforcement of the Corporate Transparency Act, following a decisive shift in the regulatory landscape under the Trump administration. This ruling allows the Financial Crimes Enforcement Network (FinCEN) to resume its mandate to collect beneficial ownership information (BOI) from certain corporate entities, a key component of the CTA aimed at enhancing transparency and reducing illicit financial activities.

Background of the CTA

The Corporate Transparency Act, enacted in January 2021, requires both U.S. and foreign entities doing business in the U.S. to report details about individuals who own or control a significant portion of the entity—specifically, those with at least 25% ownership or substantial control. These measures are designed to combat money laundering and tax evasion by closing loopholes exploited by anonymous shell companies. Compliance deadlines for initial BOI reports are set to commence from January 1, 2024, with existing companies facing a filing deadline by January 1, 2025.

Compliance Impact

With the lifting of the injunction, corporate attorneys, CPAs, and compliance officers must prepare for the immediate implications:

  • Review Compliance Protocols: Businesses should reassess their processes for collecting and reporting BOI to ensure compliance with the CTA.
  • Notify Clients: Firms must inform their clients about the resumption of reporting requirements and the potential need for updates to ownership information.
  • Monitor Future Developments: Stakeholders should stay abreast of any additional guidance or changes in the enforcement landscape as the administration continues to shape regulatory priorities.

According to Bloomberg Tax, this ruling marks a significant policy shift amidst ongoing debates regarding regulatory oversight and corporate accountability.

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