On 23 January 2025, the US Supreme Court granted the US government’s application to end the nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) issued by the District Court in Top Cop Shop on 3 December 2024. This injunction is currently on appeal with the Fifth Circuit. However, a separate nationwide order that also stayed the CTA beneficial owner reporting deadline remains in place. This order was issued by a different federal judge in Smith v. US on 7 January 2025.
The Corporate Transparency Act requires “reporting companies” to file “beneficial owner” information and “company applicants” with the Financial Crimes Enforcement Network (FinCEN) as early as 1 January 2025. In a “last minute” 3 December 2024 decision, the US District Court for the Eastern District of Texas in Top Cop Shop, Inc., et al. v. Garland, issued an order temporarily enjoining the US government from enforcing the CTA and CTA regulations