Supreme Court Ruling Adds to Corporate Transparency Act Confusion, but Filing Requirements Remain on Hold

On Jan. 23, 2025, the Supreme Court granted the government’s motion to lift a nationwide injunction issued in the case Texas Top Cop Shop, Inc. v. McHenry.

What You Need to Know
While this ruling could have potentially reinstated Corporate Transparency Act filing requirements, a separate ruling in Smith v. U.S. Department of the Treasury continues to block the enforcement of the law. As a result, businesses are not currently required to submit beneficial ownership information (BOI) reports to FinCEN, nor are they subject to penalties for failing to do so. Despite the current hold on filing requirements, businesses may still voluntarily comply should they choose.

The Bigger Picture
The Supreme Court’s decision did not address the broader legal challenges to the CTA; rather, it focused solely on whether the initial injunction should remain in place while an appeal is heard in the Fifth Circuit. Litigants in the Texas Top Cop Shop case emphasized that the ruling does not automatically lift the second injunction, meaning the future of the CTA remains uncertain. The decision now ultimately lies with the Trump administration to determine whether to extend or stay the current filing deadlines. The MRAA is hopeful that the Trump administration will provide relief for small businesses in light of ongoing litigation and widespread opposition from small businesses and community organizations.

Where Things Stand
Legal experts and industry groups continue to assess the impact of these rulings. The “Wall Street Journal” reports that Judge Jeremy Kernodle’s nationwide order from Jan. 7 still blocks CTA enforcement. Likewise, the Texas Public Policy Foundation, which represented plaintiffs in the Smith case, stated that its legal challenge remains distinct and unaffected by the Supreme Court’s ruling.

MRAA Engagement
While the CTA continues to be subject to legal review, the MRAA is continuing to work with various coalitions in pushing back against these filing requirements to provide relief for small businesses for good. Despite many key members of the Trump administration, including Vice President JD Vance and former SBA Administrator Linda McMahon, already opposing the CTA, we will continue to educate key members of Congress and the White House.

Supreme Court Ruling Adds to Corporate Transparency Act Confusion
  • 1/15/2025 – MRAA joins a letter led by the National Federation of Independent Businesses asking key members of the U.S. House and Senate to support the repeal of the CTA. View the letter.
  • MRAA joined a letter led by the National Small Business Association to President Donald J. Trump and Vice President JD Vance asking that they delay the implementation and enforcement of the CTA indefinitely. View the letter.
  • MRAA joined a letter led by the S Corp Association to the Honorable Scott Bessent, Secretary of the Treasury, highlighting the negative impact on small businesses and asking the administration to delay filing requirements until the end of the year at least. Access the letter.

What’s Next for Marine Businesses?
For marine dealers and businesses within the industry, the uncertainty surrounding the CTA means staying vigilant. While the recent FinCEN announcement provides a temporary reprieve, future changes remain possible as court battles continue. As always, the MRAA is monitoring developments closely and will provide updates as new information emerges.

In the meantime, MRAA members should stay informed and be prepared for potential shifts in compliance requirements. If you have questions about how these legal proceedings may impact your business, don’t hesitate to reach out to the MRAA Advocacy team for guidance.