News

Please read this notice in its entirety as it contains important updates to a prior alert that was issued regarding the enforcement of the Corporate Transparency Act (the “CTA”).

Yesterday we published an alert noting that the preliminary injunction enjoining enforcement of the CTA had been stayed. However, as of December 26, 2024, enforcement of the CTA is once again enjoined, meaning reporting companies need not comply with its requirements while the appeal is heard. The appeal, however, remains expedited. If the federal government were to win the appeal, the CTA and its reporting requirements (“BOI Reports”) could soon be in effect again.

While the motions panel issued a stay on the preliminary injunction on December 23, 2024, effectively reinstating the CTA and BOI Reports (see our previous alert here), the merits panel has vacated that stay via order issued December 26, 2024.

The order states that “in order to preserve the constitutional status quo while the merits panel considers the parties’ weighty substantive arguments, that part of the motions-panel order granting the Government’s motion to stay the district court’s preliminary injunction enjoining enforcement of the CTA and the Reporting Rule is VACATED.”

Michael Best has attorneys who can advise companies on the issues relating to the CTA and can help those companies comply with their reporting requirements. Please contact a member of our team for more information.