News & Analysis as of

Vacated FinCEN Injunctions

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

Jaburg Wilk on

“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

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

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...

Whiteford on

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

Cole Schotz

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

Cole Schotz on

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!

Fox Rothschild LLP on

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

Fox Rothschild LLP on

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

Allen Matkins

Update: CTA’s Beneficial Ownership Information Reporting Requirements Back On Hold; Nationwide Injunction Reinstated Following...

Allen Matkins on

This Alert is an update to our Alert dated December 24, 2024, available here and supersedes the information set forth in the December 24, 2024 Alert in its entirety. On December 26, in a rapid reversal of direction, a...more

McGlinchey Stafford

Game Off: Fifth Circuit’s Merits Panel Overturns Motions Panel; Reinstates Preliminary Injunction Staying Enforcement of the CTA

McGlinchey Stafford on

In a rollercoaster of a ride, the merits panel of the U.S. Court of Appeals for the Fifth Circuit, on December 26, 2024, vacated the prior order of the Fifth Circuit’s motions panel staying the preliminary injunction...more

Roetzel & Andress

CTA Reporting Requirements STAYED AGAIN

Roetzel & Andress on

On December 3, 2024, the U.S. District Court for the Eastern District of Texas entered an order stopping the enforcement of the Corporate Transparency Act (“CTA”) and its corresponding reporting rule. The U.S. government...more

Morrison & Foerster LLP

The Corporate Transparency Act Injunction is Back in Place

Morrison & Foerster LLP on

On December 26, 2024, a merits panel of the United States Court of Appeals for the Fifth Circuit contributed to the frenzied whirlpool of Corporate Transparency Act (CTA) developments, reversing an earlier decision to stay...more

Baker Botts L.L.P.

Fifth Circuit Reinstates Nationwide Preliminary Injunction of Corporate Transparency Act, Pausing Reporting Obligations Pending...

Baker Botts L.L.P. on

The U.S. Court of Appeals for the Fifth Circuit has reinstated the nationwide preliminary injunction preventing the federal government from enforcing the Corporate Transparency Act (“the CTA”) and the related reporting...more

Kerr Russell

Fifth Circuit Suspends Enforcement of Corporate Transparency Act

Kerr Russell on

On December 26, 2024, a panel for the U.S. Court of Appeals for the Fifth Circuit (Fifth Circuit) vacated the previous stay of the lower court’s preliminary injunction against enforcement of the Corporate Transparency Act...more

Wiley Rein LLP

… And Just Like That, CTA Is Halted (Yet Again)

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Just three days after reinstating the Corporate Transparency Act (CTA) reporting requirements, the U.S. Court of Appeals for the Fifth Circuit reversed course and vacated its own decision, thereby blocking all enforcement of...more

Cozen O'Connor

Corporate Transparency Act Injunction Reinstated

Cozen O'Connor on

On December 26, 2024, in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., Case No. 4:24-cv-478 (E.D. Tex.), the Fifth Circuit Court of Appeals reinstated the preliminary injunction prohibiting the federal...more

Lowenstein Sandler LLP

Déjà Vu All Over Again: Fifth Circuit Vacates Its Own Stay; CTA Compliance Is Now Optional Once Again (for Now)

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In a surprise ruling, December 26, the Fifth Circuit Court of Appeals vacated its own stay of the Eastern District of Texas’ Dec. 3 nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act...more

Rivkin Radler LLP

CTA Reporting Paused- Again!

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The Corporate Transparency Act (the “CTA”) has faced yet another major pivot as of Thursday, December 26, 2024: the nationwide injunction of the CTA is in effect once again. This means that the CTA and its Reporting Rule are...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

Rivkin Radler LLP

CTA Enforcement Halted Again

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In a new twist to the ongoing legal battle over the Corporate Transparency Act (CTA), the Fifth Circuit Court of Appeals has reinstated a nationwide injunction blocking its enforcement. The December 26 decision reverses a...more

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