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FinCEN Eases CTA Reporting Rules: U.S. Companies Get a Pass, Foreign Entities Get a Breather

As previewed by FinCEN and Treasury earlier this month, FinCEN announced major changes to the application of the Corporate Transparency Act. On Friday evening, FinCEN issued an interim final rule that will remove the...more

Treasury Suspends CTA Enforcement Against U.S. Citizens and Companies; Federal District Court Declares CTA Unconstitutional

The Corporate Transparency Act (the “CTA”) remains in full force and effect, although FinCEN recently announced that it will not take any enforcement actions against reporting companies who fail either to file or to update...more

Pause for Effect: Current Corporate Transparency Act Deadlines will not be Enforced

Although the Corporate Transparency Act (the “CTA”) remains in full force and effect and, along with it, a requirement for most reporting companies to file their beneficial ownership information reports, the previously...more

The Corporate Transparency Act is Back in Effect - but the New March 21, 2025, Reporting Deadline Remains Uncertain

As of February 17, 2025, the Corporate Transparency Act (the “CTA”) is back in full force and effect and, along with it, a requirement for most reporting companies to file their beneficial ownership information reports by...more

FinCEN Provides Guidance to Reporting Companies in Wake of Second Appeal to Fifth Circuit

As previously reported, the Supreme Court has already considered on an emergency basis whether to stay Corporate Transparency Act (“CTA”) enforcement deadlines. In that case, McHenry v. Texas Top Cop Shop, Inc., No. 24A653,...more

SCOTUS Stays Nationwide Injunction of the CTA; But Different District Court Nationwide Stay of Reporting Deadline Still in Effect...

As previously reported, on December 31, 2024, the government filed an application in the Supreme Court of the United States to stay or narrow the Fifth Circuit’s preliminary nationwide injunction halting the Corporate...more

To File, or Not to File: the Fifth Circuit’s Evolving Treatment of the Corporate Transparency Act

The U.S. Court of Appeals for the Fifth Circuit reinstated and then subsequently suspended the reporting requirements under the Corporate Transparency Act (the “CTA”) over the course of the last week by staying the original...more

Corporate Transparency Act: Ongoing Litigation Not Likely to Change End-of-Year Filing Dates

After the U.S. Congress enacted the federal Corporate Transparency Act (the “CTA”) on January 1, 2021, a wide range of plaintiffs immediately brought suit against the government challenging its constitutionality. Currently,...more

The CTA’s Impact on Trusts

The Corporate Transparency Act (CTA) and its reporting requirements has now gone live as of the first of this year and applies to nearly all existing and future entities (corporations, partnership and limited liability...more

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