On March 21, 2025, the Financial Crimes Enforcement Network issued an interim final rule exempting all U.S. entities and their beneficial owners from beneficial ownership information (BOI) reporting requirements under the...more
In a February 27, 2025 press release, FinCEN announced that despite the updated March 21, 2025 beneficial ownership information (“BOI”) report filing deadline, the agency will not issue any fines or penalties or take any...more
3/7/2025
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
FinCEN ,
Regulatory Requirements ,
Reporting Requirements ,
U.S. Treasury
On February 18, 2025, a Texas federal district court judge stayed the nationwide preliminary injunction on the enforcement of the Corporate Transparency Act (CTA), reinstating beneficial ownership information (BOI) reporting...more
2/21/2025
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Governance ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
FinCEN ,
Regulatory Requirements ,
Reporting Requirements
By Lawrence Sheh, Brian Reilly, and Madeline Ursini The U.S. Court of Appeals for the Fifth Circuit has reinstated a nationwide preliminary injunction on the enforcement of the Corporate Transparency Act (the “CTA”). The...more
12/31/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 23, 2024, the 5th U.S. Circuit Court of Appeals granted a stay of the nationwide preliminary injunction granted earlier this month blocking the enforcement of the Corporate Transparency Act (the “CTA”). As a...more
12/27/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
OpenAI, an artificial intelligence research nonprofit, has recently garnered media attention for considering a restructuring strategy involving the formation of a taxable subsidiary....more
On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction temporarily blocking enforcement of the Corporate Transparency Act (the “CTA”). This ruling halts the...more
This is a reminder that the January 1, 2025 deadline for filing a Beneficial Ownership Information (BOI) report under the Corporate Transparency Act (CTA) is approaching. Failure to timely file with the U.S. Treasury’s...more
In Connelly vs. United States (602 U.S. 257, June 6, 2024), the Supreme Court unanimously ruled that in a redemption of a deceased shareholder’s shares of stock, the corporation’s fair market value should include the proceeds...more
This is a reminder that pursuant to the Corporate Transparency Act (“CTA”), most new and existing business entities are required to submit a beneficial ownership information (“BOI”) report to the Financial Crimes Enforcement...more
Beginning on January 1, 2024, the vast majority of new and existing business entities will become subject to beneficial ownership information reporting requirements under the Corporate Transparency Act and its related rules...more
The Department of Commerce’s Bureau of Economic Analysis (“BEA”) conducts a benchmark survey on foreign direct investment every 5 years. The BE-12 survey is the BEA’s most comprehensive survey and produces statistics on the...more
In 2021, as part of the Anti-Money Laundering Act of 2020, Congress enacted the Corporate Transparency Act in an effort to prevent and combat illicit activities such as money laundering, terrorist financing, corruption, and...more
On December 9, 2020, the Small Business Administration (the “SBA”) released Paycheck Protection Program (“PPP”) Loans FAQ #53, which provides additional information regarding the Loan Necessity Questionnaires (SBA Forms 3509...more
When tragedy hits, there are always nefarious people who will try to profit. The ongoing COVID-19 pandemic is no exception.
There have been recent instances in which scammers have successfully used publicly available...more
On August 26, 2020, Jay Clayton, Chairman of the U.S. Securities and Exchange Commission (SEC), released a Statement on Modernization of the Accredited Investor Definition. This Statement reflects the SEC’s commitment to...more
There has been recent attention, both in the media and by the Small Business Administration (SBA), on the good faith certification required by applicants for Paycheck Protection Program (PPP) loans. The loan application...more
In our previously published client alerts regarding the coronavirus, we highlighted the importance of reviewing the terms of existing agreements in light of the threats posed by novel coronavirus COVID-19 (“coronavirus”)....more
As businesses contend with the uncertainty caused by the novel coronavirus (COVID-19), evidenced by warnings of an imminent recession and empty grocery store shelves, one potential source of relief is the force majeure clause...more
With anxiety over a potential coronavirus (also known as COVID-19) pandemic spreading more quickly than the virus itself, people across the United States are being advised to take the common-sense approaches of washing their...more
With the start of the New Year comes the enforcement of one of the country’s most anticipated pieces of legislation, the California Consumer Privacy Act (CCPA). In many ways, the CCPA is similar to its European counterpart,...more
When starting a company, founders are immediately faced with a series of decisions, many of which will have long-lasting impacts that may not become apparent for months or years. Founders need to decide in which state to form...more
We routinely recommend to clients that they develop a written information security program (“WISP”), to safeguard sensitive information on a day-to-day basis. In fact, businesses (wherever located) that collect, store or use...more
Too many closely-held businesses suffer from poorly drafted operating or shareholder agreements, or have no written agreements in place at all. Without good documentation, there is no road map to guide the partners when the...more
Privacy protection continues to be a theme at the Rhode Island General Assembly. As we reported in our April 1, 2019 Client Alert, the “Consumer Privacy Protection Act” was introduced on March 29, 2019 proposing more...more