On February 17, 2025,[2] the U.S. District Court for the Eastern District of Texas, before which is pending the Smith v. U.S. Department of the Treasury dispute, lifted the preliminary injunction it issued January 7, 2025, against the Reporting Rules[3] adopted pursuant to the Corporate Transparency Act (“CTA”),[4] thereby clearing the way for enforcement of the CTA and its filing obligations. With that action, the last pending judicial barrier to broad enforcement of the CTA’s reporting obligations was lifted, and its general enforcement recommenced.
That was, however, far from the final development with respect to the implementation of the CTA. Rather, over the first weekend of March, the government and a variety of public officials, including the current chief executive of the United States, issued a series of pronouncements as to the CTA’s reach and enforcement that ultimately foreshadow the intention to abdicate much of its enforcement. The same week, another federal district court became the first to find that the CTA violates the Fourth Amendment right against unreasonable search and seizure.
