CTA Game, Set, Match?
A great start to the week! The Corporate Transparency Act (CTA) has played out like an exhausting tennis match—rallies, pauses, reinstatements, and more pauses—only for what now appears to be the final set. In a stunning turn of events, after last week when FinCEN announced the reinstatement of the filing deadline, the CTA now appears to be permanently suspended! According to the Treasury Department, enforcement of the CTA is now officially suspended. We believe this marks the definitive conclusion to what has been a long and winding regulatory battle.
While the CTA remains on the books, its enforcement against domestic corporations and U.S. citizens is now on indefinite hold. The reporting requirements will still apply to foreign corporations, but for our community association clients and other domestic entities, we do not anticipate enforcement ever being reinstated.
At the overwhelming request of our clients, we had agreed to take on these filings—even though the back-and-forth, rule changes, and delays made it far more of an effort. That said, given the brand new update from the US Treasury Department, we are officially placing all filings on permanent hold. And in fact, while most filings are fully prepared and ready for submission to FinCEN, we have not actually hit the “submit” button on any of them. This means that our clients’ personal information has not been turned over to the federal government.
For now, it appears the CTA saga has reached its final conclusion. Should anything change (again), we will keep you updated. But for now, we’re closing out this match with a well-earned sigh of relief and is “match point”.
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