Corporate Transparency Act Reporting Requirements Back On Hold

On December 26, 2024, the merits panel of the Fifth Circuit Court of Appeals vacated the stay of the district court's preliminary injunction enjoining enforcement of the Corporate Transparency Act (the "CTA") and the reporting requirements thereunder that was issued earlier this week by the motions panel of the Fifth Circuit Court of Appeals. This means that the nationwide preliminary injunction issued by the district court on December 3, 2024 is back in effect and, for the time being, Reporting Companies are not required to comply with the Act or file Beneficial Ownership Information Reports ("BOI Reports").

When the motions panel of the Fifth Circuit Court of Appeals stayed the preliminary injunction of the CTA and reinstated the reporting requirements thereunder earlier this week, it also expedited the appeal of the district court ruling. The merits panel of the Fifth Circuit Court of Appeals now has the appeal and decided yesterday that, in order to preserve the