The Corporate Transparency Act (“CTA”) has been on a journey this past month with a whirlwind of court rulings: halted by a federal district court, reinstated by the Fifth Circuit’s motions panel, had its reporting deadlines...more
Late on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed its own decision from earlier in the week, reinstating the nationwide preliminary injunction preventing the enforcement of the Corporate...more
On December 26, 2024, the Fifth Circuit Court of Appeals reinstated the nationwide preliminary injunction blocking enforcement of the Corporate Transparency Act (CTA). This decision was made to "preserve the constitutional...more
On December 26, 2024, the US Court of Appeals for the Fifth Circuit changed course, effectively reinstating the preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA)....more
On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit issued an unsigned order in Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, reversing its prior December 23 order lifting the preliminary injunction...more
Here’s a brief recap of the CTA drama to date: On December 3, 2024, in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., the U.S. District Court for the Eastern District of Texas found the Corporate...more
In a highly unusual and unexpected order, late on December 26, 2024, a “merits panel” of the Fifth Circuit (made up of different judges than the “motions panel” that stayed the nationwide preliminary injunction on December...more
If you are feeling a bit of whiplash today, you are not alone. The United States Court of Appeals for the Fifth Circuit has reinstated a preliminary nationwide injunction of the Corporate Transparency Act (“CTA”)....more
Shortly after publication of our December 23, 2024 Client Alert regarding the Fifth Circuit’s reinstatement of the CTA, FinCEN issued guidance administratively extending the deadlines for certain BOI Report filings. Most...more
On Monday, December 23, 2024, the Fifth Circuit Court of Appeals issued an order reviving the January 1, 2025, deadline for reporting companies to file beneficial ownership information reports with the Financial Crimes...more
As previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction on the enforcement of the Corporate Transparency Act (the “CTA”) and its...more
On December 23, 2024, in response to an emergency motion by the US Department of Justice, the US Court of Appeals for the Fifth Circuit stayed the nationwide preliminary injunction against enforcement of the Corporate...more
On December 3, 2024, a US District Court in Texas ruled the Corporate Transparency Act unconstitutional and issued a nationwide preliminary injunction against its enforcement. That ruling was promptly appealed, and on...more
On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the district court’s preliminary injunction enjoining the Corporate Transparency Act (CTA) entered in the case of Texas Top Cop Shop,...more
Yesterday afternoon, on December 23, the U.S. Court of Appeals for the Fifth Circuit issued a per curiam opinion (signed by Judges Stewart, Hayes and Higginson) staying the preliminary injunction previously entered in the...more
Earlier this month, we reported that the United States District Court for the Eastern District of Texas issued a nationwide preliminary injunction prohibiting the enforcement of the Corporate Transparency Act (CTA) and...more
This alert has been updated to reflect FinCEN’s extension of the deadline after the alert was first sent. On December 23, 2024, after expedited briefing, a three-judge panel of the Fifth Circuit in Texas Top Shop v....more
The nationwide injunction against enforcement of the Corporate Transparency Act (“CTA”) and its beneficial ownership information (“BOI”) reporting rule under 31 CFR 1010.380 (the “Rule”) has been stayed pending appeal, and...more
The U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking on September 27, 2023 to amend the final Beneficial Ownership Information (“BOI”) Reporting Rule to...more