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The Corporate Transparency Act (CTA), enacted in 2021, mandates that companies disclose their true ownership to the Financial Crimes Enforcement Network (FinCEN) to combat illicit financial activities. However, its...more
On February 18, 2025, the U.S. District Court for the Eastern District of Texas (EDTX) lifted the nationwide injunction to the Financial Crimes Enforcement Network's (FinCEN) enforcement of the Beneficial Ownership...more
A Texas federal judge has ordered a stay of a nationwide injunction that placed the Corporate Transparency Act’s (“CTA”) filing requirements on hold. As a result, the CTA’s reporting requirements are back in effect. FinCEN...more
Companies are once again required to comply with the CTA and its reporting obligations. As discussed in our previous update, last month the Supreme Court of the United States (SCOTUS) stayed (i.e., suspended the effect of)...more
In the latest twist on the back-and-forth CTA battle, on January 23, 2025, the Supreme Court of the United States (SCOTUS) once again stayed (i.e., suspended the effect of) the nationwide preliminary injunction against...more
UPDATE: Please note there is a preliminary injunction against enforcement of the Corporate Transparency Act. The injunction, which applies nationwide, was granted by a Texas federal district court and such injunction has...more
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
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
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
On December 26, 2024, the Fifth Circuit Court of Appeals vacated its earlier stay of the injunction suspending the reporting deadlines for the Corporate Transparency Act (the “CTA”)....more
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
What happened now? On December 26, 2024, and only three days after lifting the nationwide injunction pending appeal, the merits panel of the U.S. Court of Appeals for the Fifth Circuit reinstated a nationwide injunction...more
On December 26, 2024, in its second order of the week related to Texas Top Cop Shop, Inc. et al. v. Garland et al., No. 4:24-CV-478 (E.D. Texas 12/3/24), the Fifth Circuit Court of Appeals restored the District Court’s...more
By Lawrence Sheh, Brian Reilly, and Madeline Ursini 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...more
Enforcement of the Corporate Transparency Act (the “CTA”) has again been halted. On December 26, 2024, the United States Court of Appeals for the Fifth Circuit vacated its own stay order entered three days earlier. The most...more
On December 26, 2024, a panel of the US Court of Appeals for the Fifth Circuit vacated an order issued by a different panel just days before that had stayed the nationwide preliminary injunction suspending enforcement of the...more
The CTA madness continues. On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit (the "Fifth Circuit"), in the case of Texas Top Cop Shop v. Garland ("Texas Top Cop Shop"), stayed the enforcement of an...more
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
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
The status of the preliminary injunction which paused the nationwide enforcement of the Corporate Transparency Act and its implementing rules (collectively, the “CTA”) continues to keep all interested parties on the edge of...more
On December 26, 2024, a merits panel of the Fifth Circuit Court of Appeals vacated the stay entered on December 23, 2024, by its own motions panel against the December 3, 2024, nationwide injunction of the Corporate...more
This is an important update to our December 6 eAlert on the nationwide injunction suspending the Corporate Transparency Act (CTA). (The CTA requires that corporations, LLCs and other business entities report to the Treasury’s...more
While the Fifth Circuit Court of Appeals considers the constitutionality of the Corporate Transparency Act (CTA) (in Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, 2024 WL 5203138), it has reinstated the nationwide...more
On December 27, 2024, a different panel of the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the earlier order of December 23, 2024, granting a stay of the preliminary injunction. For more detail and...more
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