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 Transparency Act (CTA) and its Reporting Rule to “preserve the constitutional status quo” pending the outcome of the appeals in the case of Texas Top Cop Shop, Inc. v. Garland, No. 24-40792.

What does this mean for impacted companies? 

As a practical matter, the nationwide injunction entered on December 3 against the CTA that originated in the U.S. District Court for the Eastern District of Texas is now back in effect, and BOI reporting is not required at this time.

Impacted companies may gratuitously report, if desired, or avail themselves of the suspended reporting obligations pending the outcome of the expedited appeal.

We will continue to monitor the developments in this arena.