As Dilworth Paxson advised our clients, on December 26, 2024,
the full Fifth Circuit Court reversed a three-judge panel of the
U.S. Court of Appeals for the Fifth Circuit, reinstated an
injunction against enforcement of the Corporate Transparency Act
("CTA"), and again halted the enforcement of the CTA
nationwide, while the merits of the case are under expedited
appellate review inTexas Top Cop Shop, Inc., et al. v. Garland,
et al. The underlying District Court order temporarily blocked
the enforcement of the CTA and its Beneficial Ownership Information
Report ("BOIR") filing obligations.
However, on January 23, 2025, the Supreme Court reversed the
Fifth Circuit and reinstated the enforcement of the CTA nationwide,
while the merits of the case are under expedited appellate review.
In response, FinCen released a statement January 24, 2025, stating
that because a separate nationwide injunction issued by a different
Texas court remains in place, reporting companies are
