News & Analysis as of

Vacated FinCEN

McGuireWoods LLP

Texas Court Vacates Nationwide Injunction Staying the CTA, Deadline to Report Beneficial Ownership Information is March 21, 2025

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In our last update, we reported that despite the Supreme Court staying the nationwide injunction against FinCEN’s enforcement of the CTA in one Texas case, a nationwide stay of the Reporting Rule granted by a federal judge in...more

Jaburg Wilk

CTA Filing Requirement Halted Again

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“In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in...more

Shipman & Goodwin LLP

Corporate Transparency Act - The Gift that Keeps on Giving - Government Appeals to the U.S. Supreme Court to Eliminate Nationwide...

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Not content to have an expedited hearing in March on the merits of the case at the Fifth Circuit Court of Appeals regarding the constitutionality of the Corporate Transparency Act (CTA), the Government filed an application...more

Willcox & Savage

The Corporate Transparency Act – Current Status and State of Play as of New Year’s Day 2025

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December 2024 gave businesses and practitioners whiplash trying to follow the bouncing ball about whether the Corporate Transparency Act was enforceable or unconstitutional. This article summarizes the events of the past...more

Ruder Ware

The CTA Journey – It Goes On and On and On

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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

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Court of Appeals Vacates Its Own Stay Rendering the Corporate Transparency Act Unenforceable . . . Again

On December 26, 2024, in Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, 2024 WL 5224138 (5th Cir. Dec. 26, 2024), a merits panel of the United States Court of Appeals for the Fifth Circuit issued an order vacating the...more

Sullivan & Worcester

Breaking: Corporate Transparency Act on Hold Again

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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

UB Greensfelder LLP

Fifth Circuit Court of Appeals Reinstates Nationwide Injunction Blocking Enforcement of the Corporate Transparency Act

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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

Husch Blackwell LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act - UPDATED 1/2/2025

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As of the posting of this article, reporting companies nationwide do not need to comply with the Corporate Transparency Act’s (CTA) revised beneficial owner information (BOI) reporting deadlines. The Fifth Circuit will...more

Rivkin Radler LLP

The Status of the Corporate Transparency Act – It’s Not Clear

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Few would argue that the federal government does not have a legitimate interest in preventing, detecting, and punishing tax fraud, money laundering, and other financial crimes. Likewise, I imagine few would disagree with the...more

Allen Barron, Inc.

New Deadline for FinCENs BOI Report is On Hold AGAIN

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UPDATE: DECEMBER 28, 2024: In the latest twist of the FinCEN Beneficial Owners Information (BOI) report, the new deadline for FinCEN's BOI Report is on hold again....more

Ballard Spahr LLP

CTA Reporting Requirements Blocked Again

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It’s hard to keep track of the status of reporting obligations under the Corporate Transparency Act (CTA) these days, but in a second ruling during the holiday week, a court blocked the filing requirement again. ...more

Greenbaum, Rowe, Smith & Davis LLP

Another Urgent Update on the Corporate Transparency Act: Nationwide Injunction Back in Effect – All CTA Reporting Stayed

In an Alert earlier last week, we reported that on December 23, 2024, a motion panel of three judges from the U.S. Court of Appeals for the Fifth Circuit granted the Department of Justice’s (DOJ) motion for a stay, or...more

Whiteford

Client Alert: Corporate Transparency Act: Nationwide Injunction Restored; Filing Deadlines Paused - Update – Fifth Circuit...

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The ongoing legal saga in the federal courts surrounding the Corporate Transparency Act (CTA) (31 U.S.C. § 5336) has reversed course, yet again. On December 26, 2024, the United States Court of Appeals for the Fifth...more

Bracewell LLP

Further Action From the Fifth Circuit Renders the Corporate Transparency Act Unenforceable Nationwide

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On December 26, 2024, a merits panel for the US Court of Appeals for the Fifth Circuit (Fifth Circuit) vacated the previously reported December 23, 2024 stay, giving new life to the nationwide preliminary injunction of the...more

Seward & Kissel LLP

UPDATE - CTA Whiplash; Fifth Circuit Reverses itself and Blocks Corporate Transparency Act Reporting Requirements

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On December 26, 2024, in a very short opinion, the U.S. Court of Appeals for the Fifth Circuit, which on December 23 had lifted a national stay imposed by the U.S. District Court for the Eastern District of Texas in the case...more

McNees Wallace & Nurick LLC

Continued commotion in Corporate Transparency Act compliance

Beneficial owners of reporting companies, as defined under the Corporate Transparency Act (31 U.S.C. § 5336) (the “CTA”), and anyone closely following recent activity surrounding the CTA and its Reporting Rule, are likely...more

Foster Garvey PC

Fifth Circuit Lifts Stay of Injunction of CTA

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On December 26, 2024, the Fifth Circuit Court of Appeals vacated its stay of the preliminary injunction of the Corporate Transparency Act (“CTA”), 31 U.S.C. § 5336. This decision reinstates the injunction nationwide, meaning...more

Dickinson Wright

Fifth Circuit Reinstates CTA Injunction, FinCEN Still Accepting Voluntary Filings

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In a surprising reversal, on December 26, 2024, a panel of the Fifth Circuit Court of Appeals issued an Order that vacated (effectively reversing) the same court’s order from December 23, 2024, and reinstated a lower court’s...more

Eversheds Sutherland (US) LLP

Fifth Circuit changes course—CTA preliminary injunction reinstated

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

Perkins Coie

Corporate Transparency Act: Court Swiftly Reimposes Injunction Against Enforcement

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As reported in our recent Update, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the...more

Cole Schotz

Fifth Circuit Changes Its Mind. CTA Filings Not Required Pending Further Review

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On December 26, 2024, in an Order entered “at the direction of the Court,” the Fifth Circuit Court of Appeals vacated its own stay of District Judge Amos Mazzant’s nationwide injunction of the Corporate Transparency Act...more

Fox Rothschild LLP

After a Dizzying Series of Court Twists, the CTA is Halted. Again!

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Key Takeaway: A Texas federal judge issued a nationwide injunction, but it was stayed by an appeals court. Now that stay has been lifted — so the injunction is in force again. As the year-end filing deadline approached for...more

Vinson & Elkins LLP

Fifth Circuit Vacates Stay of Injunction Against Enforcement of the Corporate Transparency Act – Nationwide Preliminary Injunction...

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As we previously discussed, on December 5, 2024, the Department of Justice (“DOJ”), representing the Department of the Treasury, submitted a notice of appeal to the U.S. Court of Appeals for the Fifth Circuit, challenging a...more

Fox Rothschild LLP

After a Series of Court Twists, the Corporate Transparency Act is Halted Again

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As the year-end filing deadline approached for the Corporate Transparency Act (CTA), we've seen a dizzying series of court rulings that put a freeze on any enforcement of the law with a preliminary injunction, then stayed...more

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