By Jessica S. Kaczinski and Ian T. ReillyIn a truly unexpected turn of events, the Corporate Transparency Act (CTA) is once again on hold. As we reported to you just days ago, on Monday December 23, 2024, the Fifth Circuit Court of Appeals stayed the nationwide preliminary injunction issued by a Texas judge earlier in December – effectively reinstating enforcement of the CTA. In addition to staying the injunction, the Court also granted an expedited appeal, allowing this case to be heard in the next available oral argument period.Three days later, that all changed. On Thursday December 26, 2024, a different group of judges, called the “merit panel”, from very same Fifth Circuit Court of Appeals in reviewing the December 23 decision of the “motions panel” has elected to reinstate the nationwide preliminary injunction “in order to preserve the constitutional status quo while the merits panel considers the parties’ weighty substantive arguments.” This is a sharp departure from the language of the Court’s previous order, which weighed heavily in the Government’s favor.While we covered what this injunction means for you in previous posts, to reiterate here – at the moment, if you have not already filed your Beneficial Ownership Information (BOI), this injunction means that filing deadline is once again on an indefinite hold. With both the initial filing deadline and the modified deadline of January 13, 2025, that we discussed in our prior post set to pass before the next session of the Supreme Court in January, we expect that if any decision is made in the future to reinstate the CTA, it will be done on a heavily modified timetable.As we’ve recommended previously, given this uncertainty, while we recommend no immediate filing action at this time, it would be prudent to continue preparing your materials so you’re ready to act should the injunction be lifted.If you’ve already filed your BOI, you’re ahead of the curve and well-prepared for any outcome, and you need to do nothing at this time. When you filed your BOI, you did so in compliance with Federal law, and if this case is resolved sometime in the future in favor of the Federal government, you will remain in compliance with that law.We will continue to keep you apprised of what has evolved into a rapidly changing situation, though we personally hope to report no additional information until the appeal is fully resolved, we’ll be sure to update you as the situation continues to evolve and your obligations continue to change. If you have concerns or questions about how this injunction affects your specific situation, contact your Gross McGinley attorney today.