News & Analysis as of

Vacated FinCEN Appellate Courts

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

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

Holland & Hart LLP

CTA Whiplash: Fifth Circuit Reinstitutes Nationwide CTA Injunction

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On December 26th, just three days after the United States Court of Appeals for the Fifth Circuit effectively reinstated reporting obligations under the Corporate Transparency Act (CTA), the Fifth Circuit has now vacated its...more

Moritt Hock & Hamroff LLP

CTA Stayed Once Again – No BOI Reports Required At This Time

On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reinstated the nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act (the “CTA”) and the rules and regulations...more

Best Best & Krieger LLP

Corporate Transparency Act Back and Forth Continues – 5th Circuit Reinstates Injunction

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On December 26, 2024, the United States Court of Appeals for the Fifth Circuit (Fifth Circuit) vacated its December 23, 2024 order which reinstated filing obligations under the Corporate Transparency Act (CTA). The Fifth...more

Rothwell, Figg, Ernst & Manbeck, P.C.

Latest Update: Corporate Transparency Act Halted Again

Only days after lifting the nationwide preliminary injunction, the Fifth Circuit Court of Appeals vacated their decision to stay the district court’s preliminary injunction enjoining enforcement of the Corporate Transparency...more

Adams & Reese

“Christmas Chaos Continues” – Fifth Circuit Panel Blocks CTA Again as Filing Requirements Suspended

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Updated with FinCEN Response to Dec. 26 Fifth Circuit Decision - Chaos is officially the perfect word to describe the situation around the Corporate Transparency Act (“CTA”)...more

Chambliss, Bahner & Stophel, P.C.

Corporate Transparency Act Blocked Again by the Fifth Circuit

On December 26, 2024, three days after a Fifth Circuit panel lifted the nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA), a different panel of the same court vacated the stay order...more

Neal, Gerber & Eisenberg LLP

Corporate Transparency Act Filing Requirements and Deadlines Again On Hold

On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit entered an order that has the effect of again prohibiting the enforcement of the Corporate Transparency Act (CTA) and staying all CTA filing deadlines. A...more

Proskauer Rose LLP

On Again, Off Again: Corporate Transparency Act Injunction Back in Effect

Proskauer Rose LLP on

On December 26, 2024, the Fifth Circuit of the United States Court of Appeals vacated the stay of the injunction on the Corporate Transparency Act (the “CTA”) that a panel had issued earlier in the week. As a result, the...more

White and Williams LLP

Corporate Transparency Act Déjà vu – The More Things Change The More They Stay The Same

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The reporting requirements of the Corporate Transparency Act (“CTA”) are once again paused, according to a decision from the United States Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) filed on December 26,...more

ArentFox Schiff

Does Your Neck Hurt? — Fifth Circuit Reverses Itself on Corporate Transparency Act Injunction

ArentFox Schiff on

Adding yet another chapter to the Corporate Transparency Act (CTA) saga, the US Court of Appeals for the Fifth Circuit on December 26 issued an order vacating its stay of the Texas federal district court’s preliminary...more

Pierce Atwood LLP

Corporate Transparency Act Whiplash: Fifth Circuit Reinstates Preliminary Suspension of Deadline Pending Merits Ruling

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On December 3, 2024, the Eastern District of Texas issued a nationwide preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA), less than a month before the deadline. The ruling temporarily...more

Snell & Wilmer

The Never-Ending Revolving Door: The Corporate Transparency Act Is On Ice (Again)

Snell & Wilmer on

On December 26, 2024, the merits panel of the United States Court of Appeals for the Fifth Circuit issued an order vacating the earlier motions panel’s order from December 23, 2024, that had granted a stay of the nationwide...more

King & Spalding

CTA Preliminary, Nationwide Injunction Reinstated; FinCEN Suspends Compliance with CTA; Briefing Schedule on the Merits...

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On December 26, 2024, a three-judge “merits panel” for the U.S. Court of Appeals for the Fifth Circuit vacated the December 23, 2024, order issued by a separate three-judge “motions panel,” which had granted the government’s...more

Warner Norcross + Judd

CTA Reporting Obligations Again Suspended

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Our roller coaster ride with the Corporate Transparency Act (CTA) continues. On Dec. 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated its Dec. 23 order staying the prior injunction in Texas Top Cop Shop, Inc....more

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