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FinCEN Adopts Interim Final Rule Limiting CTA Reporting Requirements to Foreign Reporting Companies

US legal entities are no longer subject to the reporting requirements of the Corporate Transparency Act (CTA). On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of Treasury...more

Another CTA Freeze: Treasury Department Announces Suspension of Enforcement Against Domestic Reporting Companies

If you have been following our reports on the subject, you know that the Corporate Transparency Act (CTA) had a tumultuous end to 2024 and start to 2025, with a series of court actions leading to oscillating reports about...more

Corporate Transparency Act Reporting Obligations Effective Again With March 21, 2025, Deadline for Most Reporting Companies

On February 17, 2025, the US District Court for the Eastern District of Texas (EDTX) in Smith, et. al. v. US Department of the Treasury, et. al., entered an order staying the nationwide injunction on enforcement of the...more

Further Action From the Fifth Circuit Renders the Corporate Transparency Act Unenforceable Nationwide

On December 26, 2024, a merits panel for the US Court of Appeals for the Fifth Circuit (Fifth Circuit) vacated the previously reported December 23, 2024 stay, giving new life to the nationwide preliminary injunction of the...more

Corporate Transparency Act Enforceable With Extended Deadlines Following Actions of Fifth Circuit and FinCEN  

On December 23, 2024, the US Court of Appeals for the Fifth Circuit granted an emergency motion for a temporary stay pending appeal requested by the federal government. The government submitted the motion in connection with...more

Texas Court Issues Nationwide Preliminary Injunction of the Corporate Transparency Act

On December 3, 2024, the US District Court for the Eastern District of Texas issued a nationwide preliminary injunction, halting enforcement of the Corporate Transparency Act (CTA) and its implementing regulations....more

Federal Judge Rules Corporate Transparency Act Is Unconstitutional: Takeaways and Next Steps

On March 1, 2024, the US District Court for the Northern District of Alabama granted summary judgment to Issac Winkles and the National Small Business Association (NSBA), holding that the Corporate Transparency Act (CTA) is...more

Beneficial Ownership Information Reporting Under the Corporate Transparency Act

On January 1, 2024, the reporting requirements under the Corporate Transparency Act (CTA) became effective. The CTA was enacted by Congress on January 1, 2021, as part of the Anti-Money Laundering Act of 2020 and requires...more

SEC Staff Revises Guidance on Shortened Debt Tender Offers, Expands Guidance to Cover Tender Offers for High-Yield Debt and...

The staff of the Securities and Exchange Commission recently issued a no-action letter that substantially revises its long-standing guidance for shortened tender offers for non-convertible debt securities. The letter permits...more

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