Dear Friend,

Subsequent to last week’s Alert, a different panel of the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the Court’s December 23, 2024, order granting a stay of the preliminary injunction in regard to the Corporate Transparency Act.  

Translation:   

The injunction blocking enforcement of the CTA and the mandatory filing of beneficial ownership information reports, which was issued by the district court in Texas Top Cop Shop, Inc. v. Garland is in effect. 

Therefore, reporting companies are not currently required to file BOIRs with FinCEN. 

However, the government has filed with the U.S. Supreme Court in an attempt to overturn the most recent order and again put the CTA and BOI reporting back into play. 

We’ll send updates as the situation changes.