News & Analysis as of

Preliminary Injunctions Stays Filing Deadlines

Bricker Graydon LLP

The CTA is Back in Play, with a Slight Extension

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CTA Update – On Tuesday, February 18, 2025, the US District Court for the Eastern District of Texas stayed its order from January 7, 2025, which provided a nationwide injunction on the CTA’s enforcement....more

Dorsey & Whitney LLP

FinCEN Confirms New CTA Filing Deadline - But Congress Looks to Push Deadlines For Some Reporting Entities to 2026

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On February 18, 2025, in a widely expected decision, the Eastern District of Texas, in the case of Smith v. United States Dep't of the Treasury, 2025 WL 41924 (E.D. Tex.), and following the decision of the U.S. Supreme Court...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

Jaburg Wilk

CTA Beneficial Ownership Reporting Requirements Reinstated – With Deadline Extensions

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The Fifth Circuit has removed the nationwide injunction concerning Corporate Transparency Act reporting. The Fifth Circuit’s decision overrides the earlier nationwide relief granted by the district court. Litigation will...more

Lerman Senter PLLC

Fifth Circuit Reinstates Stay on Ownership Reporting - Deadline Lifted

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On December 26, 2024, the Fifth Circuit reinstated a stay of the Corporate Transparency Act’s requirement that businesses must file Beneficial Ownership Information reports. Accordingly, there is at present no obligation to...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

Womble Bond Dickinson

Update: CTA Filing Requirements Are "On" - Compliance Required by January 13, 2025 (for most reporting companies)

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On December 23, 2024, the Court of Appeals for the Fifth Circuit stayed the nationwide injunction enjoining the U.S. government from enforcing the Corporate Transparency Act (the “CTA”) and the corresponding reporting...more

BCLP

To File, or Not to File: the Fifth Circuit’s Evolving Treatment of the Corporate Transparency Act

BCLP on

The U.S. Court of Appeals for the Fifth Circuit reinstated and then subsequently suspended the reporting requirements under the Corporate Transparency Act (the “CTA”) over the course of the last week by staying the original...more

Womble Bond Dickinson

CTA UPDATE: No Action Needed Yet - Mandatory CTA Filings are “OFF” For Now

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On December 26, 2024, the Court of Appeals for the Fifth Circuit VACATED a ruling early this week to stay the nationwide injunction enjoining the U.S. government from enforcing the Corporate Transparency Act (the “CTA”) and...more

Epstein Becker & Green

Enforcement of CTA Halted Yet Again After Federal Court Reverses Course and Reinstates Nationwide Injunction

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On December 26, 2024, in a surprising move, the U.S. Court of Appeals for the Fifth Circuit issued a decision reinstating the nationwide injunction against enforcement of reporting requirements for beneficial ownership...more

Winstead PC

News Alert: Fifth Circuit Reinstates Beneficial Ownership Reporting Injunction

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Late on December 26, 2024, a panel of the Fifth Circuit ordered the injunction back into effect. Timing is uncertain for any oral arguments or other court rulings....more

Parker Poe Adams & Bernstein LLP

Corporate Transparency Act Filings Are Back on Hold

In an unusual turn of events, the Fifth Circuit Court of Appeals has reversed itself and put the Corporate Transparency Act (CTA) back on hold....more

Dorsey & Whitney LLP

CTA Compliance Paused Yet Again - Federal Appeals Court Reinstates Temporary Nationwide Injunction

Dorsey & Whitney LLP on

As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the Corporate Transparency Act (“CTA”). Texas Top Cop...more

Kaufman & Canoles

The Corporate Transparency Act Filing Deadline Stayed Once Again

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On Thursday, December 26, 2024, the United States Court of Appeals for the Fifth Circuit reinstated the nationwide injunction staying the CTA filing deadline....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

Perkins Coie on

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

Benesch

On Hold AGAIN - CTA Preliminary Injunction Reinstated

Benesch on

As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction blocking the U.S. Department of Treasury from enforcing the Corporate...more

Miller Canfield

Fifth Circuit Reinstates Texas Federal District Court’s Nationwide Preliminary Injunction and Stay of the Corporate Transparency...

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Late in the day on December 26, 2024, the United States Court of Appeals for the Fifth Circuit reinstated a nationwide injunction staying enforcement of the Corporate Transparency Act (CTA) and its reporting rules and...more

Holland & Knight LLP

Corporate Transparency Act: Nationwide Injunction in Place Again; All Filing Deadlines Suspended

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In a continuing series of dizzying judicial actions, the U.S. Court of Appeals for the Fifth Circuit on Dec. 26, 2024, vacated the stay and reinstated the nationwide preliminary injunction enjoining enforcement of the...more

Venable LLP

Fifth Circuit Reimposes Nationwide Preliminary Injunction

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After a rollercoaster ride last week, the Corporate Transparency Act's (CTA) nationwide preliminary injunction remains in place for the immediate future, pending further review by the U.S. Court of Appeals for the Fifth...more

Greenberg Glusker LLP

Fifth Circuit Lifts Injunction on Corporate Transparency Act

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The Financial Crimes Enforcement Network (FinCEN) beneficial ownership reporting deadline has been elusive in December 2024. The “fun” began when the District Court presiding over the Texas Top Cop Shop case enjoined...more

Bass, Berry & Sims PLC

Fifth Circuit Reinstates Injunction Halting Enforcement of Corporate Transparency Act

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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

Bradley Arant Boult Cummings LLP

Should I Stay or Should I Go? Reporting Companies Are (Again) Not Required to Comply with the CTA

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

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