Corporate Transparency Act Halted Again

On December 3, 2024, a Texas federal court issued a nationwide injunction that temporarily halted the implementation and enforcement of the Corporate Transparency Act (the “CTA”). Then, on December 23, 2024, a motions panel of the Fifth Circuit Court of Appeals issued an order staying the lower court’s injunction, effectively reinstating the CTA. However, on December 26, 2024, a merits panel of the Fifth Circuit Court of Appeals vacated the motions panel order that stayed the injunction. As a result, the CTA currently remains temporarily halted. All obligations and filing requirements under the CTA are voluntary and companies are not currently required to comply. As courts continue to review and rule on the CTA, the status is likely to keep changing. We will continue to monitor the changes, but recommend companies remain ready to comply with short notice.

If you have any questions about how this impacts your company specifically, please reach out to your primary contact at Gray Ice Higdon or a member of our CTA Group: Casner Wheelock, Matt Dearmond, Anna Deye, and Janis Howard.

Disclaimer: This summary is current as of January 7, 2025. It does not contain all aspects of the applicable rulings or the CTA and is subject and likely to change. The information contained in this communication is not legal advice and is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties under or related to the CTA.