Fifth Circuit Vacates Stay of CTA Preliminary Injunction, Halting Enforcement

On December 26, 2024, the Fifth Circuit vacated the stay of a preliminary injunction against enforcement of the Corporate Transparency Act (CTA) and its Reporting Rule. This order reinstates the December 3 injunction issued by the District Court for the Eastern District of Texas in Texas Top Cop Shop, Inc. v. Garland.

While a motions panel initially granted the US government’s emergency motion for a stay pending appeal on December 23, the merits panel vacated the stay and reinstated the injunction. The appeal of the preliminary injunction remains expedited, with a briefing schedule forthcoming, but this order reinstates the district court’s injunction against CTA enforcement while the appeal is pending.

The enforcement status of the CTA remains subject to further court decisions and we will continue to monitor developments closely and provide updates as soon as they become available.