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Insight Corporate Transparency Act Update – Nationwide Preliminary Injunction Reinstated

By Christopher Cook, Steve Frinsko,

On December 23, 2024, we published a client alert regarding the recent preliminary injunction halting enforcement of the Corporate Transparency Act (“CTA”) and related filing deadlines.

That same day, the U.S. Court of Appeals for the Fifth Circuit entered an order lifting (i.e., staying) the nationwide preliminary injunction previously ordered by the U.S. District Court for the Eastern District of Texas.

Not three days after it issued its December 23rd order lifting the nationwide injunction on CTA reporting, the Fifth Circuit changed its mind and on December 26th vacated that order. This means that the District Court’s previous order enjoining CTA enforcement is back in effect. As a result, CTA reporting is on hold while the parties continue to litigate the issue.

The case is Texas Top Cop Shop, Inc. v. Garland, No. 4:24-CV-478, 2024 WL 5145951 (E.D. Tex. 17, 2024).

Note that the above case and injunctions only impact companies that are required to report under the CTA. Companies exempt from reporting remain exempt regardless of the outcome of this litigation.

Watch this space for more details as the litigation proceeds.


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