The court’s opinion arrives just days ahead of oral arguments scheduled for September 27 in the government’s appeal of Nat’l Small Bus. United d/b/a Nat’l Small Bus. Ass’n v. Janet Yellen before the Eleventh Circuit. In that case, the District Court for the Northern District of Alabama held the CTA to be unconstitutional on the grounds that Congress exceeded its powers to regulate interstate commerce, oversee foreign affairs and national security, and impose taxes. Notably, however, the decision was limited to the plaintiffs in that case. 6 For further details, please see our prior alerts on the CTA, including our discussion of the Northern District of Alabama opinion, here .

With the deadline of January 1, 2025, looming for entities formed prior to 2024 to file their initial reports, we encourage clients to remain compliant with the CTA’s requirements and to follow our client alerts on the subject.

1 Michael Firestone, et al. v. Janet Yellen , Case No. 3.24-cv-1034, Dkt. No. 18 (D. Or. Sept. 20, 2024).
2 Nat’l Small Bus. United d/b/a Nat’l Small Bus. Ass’n v. Janet Yellen , Case No. 5:22-cv-01448, Dkt. No. 52 (N.D. Ala. Mar. 1, 2024); see also Hearing Schedule for the United States Court of Appeals for the Eleventh Circuit, available here .
3 William Boyle v. Janet Yellen , Case No. 2:24-cv-00081 (D. Me. filed Mar. 15, 2024); Black Econ. Council of Mass., Inc. v. Janet Yellen , Case No. 1:24-cv-11411 (D. Mass. filed May 29, 2024); Small Bus. Ass’n of Mich. v. Janet Yellen , Case No. 1:24-cv-00314 (W.D. Mich. filed Mar. 26, 2024); Robert J. Gargasz Co. LPA v. Janet Yellen , Case No. 1:23-cv-02468 (N.D. Ohio filed Dec. 29, 2023); Texas Top Cop Shop, Inc. v. Merrick Garland , Case No. 4:24-cv-00478 (E.D. Tex. filed May 28, 2024); Taylor v. Janet Yellen , Case No. 2:24-cv-00527 (D. Utah filed July 29, 2024).
4 Firestone , 3.24-cv-1034, Dkt. No. 18 at 1.
5 See generally id.
6 See Nat’l Small Bus. United , Case No. 5:22-cv-01448, Dkt. No. 52 at 2 (“The Defendants, along with any other agency or employee acting on behalf of the United States, are PERMANENTLY ENJOINED from enforcing the Corporate Transparency Act against the Plaintiffs.”).

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