DECEMBER 30, 2024: As noted in our prior Client Alert, on December 26, 2024, the Fifth Circuit Court of Appeals issued an order reinstating the nationwide injunction of the Corporate Transparency Act (CTA). Companies are not required to file reports under the Corporate Transparency Act until further order of the court, although they may voluntarily do so.
On December 27, 2024, the Fifth Circuit entered a briefing schedule and set the case for oral argument as follows:
- Appellants’ brief due: February 7, 2025
- Appellees’ brief due: February 21, 2025
- Appellants’ reply brief due: February 28, 2025
- Oral argument: March 25, 2025
We expect the nationwide injunction will remain in force until sometime after oral argument on March 25, 2025, although it is possible that it will be lifted sooner.
It is unclear whether the issue will reach the U.S. Supreme Court. Justice Samuel A. Alito, Jr., is the Supreme Court Justice assigned to the Fifth Circuit.
Further information about the CTA is available on FinCEN’s website. Also, check out our prior Client Alerts about the CTA:
- Client Alert UPDATE: Fifth Circuit Court of Appeals Reinstates Injunction of CTA Reporting Requirements; Filing Again Voluntary (Dec. 27, 2024)
- Client Alert: Corporate Transparency Act Deadlines Reinstated; Short Extension Granted (Dec. 24, 2024)
- Client Alert: U.S. District Court Orders Nationwide Injunction of Corporate Transparency Act; Compliance Now Voluntary (Dec. 12, 2024)
- Client Alert: Millions of U.S. Businesses Face New 2024 Year-End Reporting Deadlines Under the Corporate Transparency Act (Oct. 10, 2024)
For CTA questions, please reach out to your Raines attorney or e-mail a member of our CTA team at RainesCTA@raineslaw.com.
The Raines CTA Team:
Derek Dundas
Email: ddundas@raineslaw.com
Direct: 310-620-9338
David Madden
Email: dmadden@raineslaw.com
Direct: 312-704-2177
Jonathan Richter
Email: jrichter@raineslaw.com
Direct: 310-730-4375
Clare McKeown
Email: cmckeown@raineslaw.com
Direct: 312-625-9048
Johnathan Jianu
Email: jjianu@raineslaw.com
Direct: 424-343-8632