CSG Law Alert: Latest CTA Update – 5th Circuit Spins Heads by Reinstating Injunction
As a continuation to our previous CSG Law Alert: CTA Injunction Lifted by Fifth Circuit – FinCEN Extends Filing Deadlines, on December 26, the Fifth Circuit Court of Appeals issued a short ruling that reinstated the preliminary injunction enjoining enforcement of the Corporate Transparency Act (“CTA”) pending expedited review of the merits of the case. As a result, although beneficial ownership information (“BOI”) reports may be filed with FinCEN, they are not required to be filed pending further court order.
In light of the Fifth Circuit’s differing opinions regarding the enforcement of the CTA and expedited merits panel review, we strongly encourage all clients to continue gathering the necessary information to complete BOI reports so they are prepared to file if the injunction is again vacated.
CSG Law will continue to monitor the status of this case, as well as any subsequent legal and administration developments.
Please contact your CSG Law attorney or the authors of this alert with any questions.