January 24, 2025: On January 23, 2025, the U.S. Supreme Court entered an order staying a nationwide injunction of the Corporate Transparency Act that had been ordered by a Texas U.S. District Court judge on December 5, 2025 in the case Texas Top Cop Shop v. Garland. However, there’s a new national injunction in place as of January 7, 2025 in the case Smith v. U.S. Department of Treasury. This injunction has not been stayed and remains in effect. On January 24, 2025, FinCEN announced that filings under the CTA will remain voluntary for now, pursuant to the Smith injunction. Raines is watching developments closely and will alert you if filing again becomes mandatory.
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