Not So Fast: Fifth Circuit Panel Vacates Prior Order; Reinstates Nationwide Injunction of CTA
December 27, 2024
In a surprise move, late on December 26, 2024, a different panel of the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the Court's prior order from December 23, 2024, granting a stay of the preliminary injunction against enforcment of the Corporate Transparency Act (CTA). Accordingly, as of December 26, 2024, the injunction issued by the district court in Texas Top Cop Shop, Inc. v. Garland remains in effect.
In light of this most recent development (and as acknowledged by FinCEN), 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 injunction remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.
Latest Insights
- Ten (Non-Tax) Reasons to Have an Estate Plan
- Not So Fast: Fifth Circuit Panel Vacates Prior Order; Reinstates Nationwide Injunction of CTA
- Corporate Transparency Act Update: Enforcement Deadlines Return Upon Dissolution of Nationwide Injunction
- Federal Court Blocks Enforcement of the Corporate Transparency Act
- CLIENT NOTICE: Compliance Deadline Under the Corporate Transparency Act Is Imminent (Updated)