The U.S. Court of Appeals for the Fifth Circuit has reinstated a nationwide preliminary injunction on the enforcement of the Corporate Transparency Act (the “CTA”). The preliminary injunction, which had previously been stayed by a three-judge panel of the Fifth Circuit, pauses the beneficial ownership information (“BOI”) reporting requirements under the CTA.
Although the CTA is not currently enforceable while the preliminary injunction is in effect, it is possible that the courts could reverse course and reinstate a stay on the preliminary injunction. Given this uncertainty, reporting companies should continue to evaluate the applicability of the CTA to their business and, if not exempt from reporting, gather the necessary beneficial ownership information to be prepared to promptly file a BOI report if the injunction is once again stayed.
