On January 23, 2025, the U.S. Supreme Court granted the Application for Stay of the Amended Order of the U.S. District Court, E.D. Texas, issued December 5, 2025 in Texas Top Cop Shop, Inc. v. Garland, No. 4:24-CV-478, 2024, that enjoined enforcement of the Corporate Transparency Act. The U.S. Supreme Court stayed the order pending disposition of the appeal in the Fifth Circuit Court of Appeals and disposition of a petition for writ of certiorari, if such a writ is timely sought.
Justice Gorsuch concurred in the stay, but indicated he would go a step further and take the case now as the government suggested, to resolve definitively whether a district court may issue universal injunctive relief. Justice Jackson dissented, opining that emergency relief is not appropriate because the applicant failed to demonstrate sufficient exigency to justify the intervention of the U.S. Supreme Court.
The decision of the U.S. Supreme Court means that enforcement of CTA requirements will proceed. As of this writing, new guidance has not been issued by FinCEN. Please refer to the FinCEN website for updates on CTA compliance.
The advise of Moseman Law Office is to delay filing regarding your LLC information until the new deadlines are set or there is additional information from the Courts.