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FinCEN Drops BOI Reporting for U.S. Companies, Keeps Rules for Foreign Entities

On March 21, FinCEN released a statement that echoes the U.S. Department of the Treasury’s announcement on March 2, removing all beneficial ownership reporting obligations for U.S. companies and persons under the Corporate...more

Corporate Transparency Act Reporting Obligations Reinstated; Deadline Extended 30 Days

On February 19, 2025, FinCEN released a statement that BOI reporting obligations under the CTA are back in effect, after a recent U.S. District Court decision in the ongoing case of Smith et al. v. U.S. Department of the...more

Corporate Transparency Act Still Enjoined Despite Supreme Court Stay Pending Fifth Circuit Ruling; FinCEN Announces BOI Reporting...

On Jan. 24, 2025, FinCEN released a statement (screenshot below) acknowledging that the Corporate Transparency Act (CTA) remains enjoined given yet another injunction that has relieved business owners across the nation from...more

Corporate Transparency Act: Fifth Circuit Panel Vacates Stay Against CTA Injunction; Reporting Obligations Again Suspended Pending...

On December 26, 2024, a merits panel of the Fifth Circuit Court of Appeals vacated the stay entered on December 23, 2024, by its own motions panel against the December 3, 2024, nationwide injunction of the Corporate...more

Corporate Transparency Act Injunction Overturned by Fifth Circuit; Companies Advised to Report by 12/31 Deadline

UPDATE: Main Reporting Deadline Extended to January 13, 2025 - On December 23, 2024, the Fifth Circuit issued an order granting a stay of the December 3 nationwide injunction against the Corporate Transparency Act (CTA) that...more

Corporate Transparency Act Enjoined Nationwide in U.S. District Court Case

Once again, the Corporate Transparency Act (CTA) has been met with a judicial roadblock, this time being enjoined nationwide and declared “likely unconstitutional.” On Dec. 3, 2024, U.S. District Court Judge Amos L. Mazzant...more

FinCEN Announces Relief Plans for Qualified Victims Impacted by Recent Hurricanes

The Financial Crimes Enforcement Network (FinCEN) recently announced plans to provide relief to victims of recent hurricanes and natural disasters, including Hurricane Helene. FinCEN is providing an additional six months to...more

Staying Compliant: Corporate Transparency Act Updates for Businesses

Since we’re closing in on the end of 2024, we want to provide this update to our clients concerning the upcoming reporting deadline under the Corporate Transparency Act (CTA). If your entity was created or registered to do...more

UPDATE: FinCEN Issues Notice Regarding the Alabama District Court’s Order Declaring the U.S. Corporate Transparency Act...

In a notice issued by FinCEN on March 4, 2024, the regulator advised that it will “comply with the court’s order for as long as it remains in effect” and will not enforce the CTA against the named plaintiffs in the instant...more

U.S. Corporate Transparency Act: Beneficial Ownership Disclosure Obligations Take Effect

Pursuant to the Corporate Transparency Act (CTA), certain “Regulated Entities” must now file information concerning their beneficial ownership information (BOI) with the Financial Crimes Enforcement Network (FinCEN) so that...more

U.S. Corporate Transparency Act: Beneficial Ownership Disclosure Obligations Commence in 2024

Pursuant to the Corporate Transparency Act (CTA), certain “Regulated Entities” must now file information concerning their beneficial ownership information (BOI) with the Financial Crimes Enforcement Network (FinCEN) so that...more

U.S. Corporate Transparency Act Reporting Requirements Saddle Start-Ups and Investors with New Mandated Federal Disclosure...

In what amounts to a significant departure from centuries of precedent, millions of private companies will soon be required to file both initial and episodic disclosure reports regarding beneficial ownership and control with...more

Delaware’s Duty of Oversight Applies to Corporate Officers

In a recent decision, the Delaware Court of Chancery determined for the first time that corporate officers owe a duty of oversight under Delaware Law. The case, In re McDonald’s Corporation Stockholder Derivative Litigation,...more

SEC Proposes Conditional Broker Registration Exemptions for 'Finders'

Earlier this month, the SEC proposed an order that would exempt “Finders” — individuals who connect private issuers with accredited investors — from federal broker registration requirements, provided that certain conditions...more

SBA Issues Affiliate Guidance for Emerging Companies and Other Small Businesses Seeking Paycheck Protection Program Loans Under...

On April 3, 2020, the Small Business Administration (SBA) released additional guidance regarding the determination of “affiliate” status for purposes of eligibility for the Paycheck Protection Program (PPP), one of the...more

Interim Update – CARES Act Considerations for Emerging Companies and Other Small Businesses: The SBA Provides High-Level Guidance...

On March 31, 2020, the Small Business Administration (SBA) released high-level guidance regarding the Paycheck Protection Program (PPP), one of the programs enacted as part of the Coronavirus Aid, Relief, and Economic...more

CARES Act Considerations for Emerging Companies and other Small Businesses

CARES ACT CONSIDERATIONS FOR EMERGING COMPANIES AND OTHER SMALL BUSINESSES: Congress provides immediate relief in the form of small business loan - As the COVID-19 pandemic continues to take its toll in the United States,...more

Primer on Corporate Freedom of Information Act (FOIA) and Confidentiality Challenges

In this era of pervasive government regulation there are a number of ways federal and state governments come into possession of sensitive private and commercial information. Given that the federal Freedom of Information Act...more

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