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New Interim Rule Removes CTA Reporting Requirements for U.S. Companies and U.S. Persons

On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule to the U.S. Corporate Transparency Act (“CTA”) that eliminates beneficial ownership...more

Treasury Announces Non-Enforcement of the Corporate Transparency Act for Domestic Entities

On March 2, 2025, the U.S. Department of the Treasury issued a press release announcing that it would not enforce any penalties or fines or take other enforcement actions against U.S. citizens or domestic reporting companies...more

Corporate Transparency Act Deadlines on Hold

On February 27, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced that it would not issue any fines or penalties or take other enforcement actions for a failure to comply...more

Round and Round We Go: Corporate Transparency Act Remains Stayed for Now, Despite U.S. Supreme Court Ruling

On January 23, 2025, the U.S. Supreme Court ruled that the federal government may enforce the Corporate Transparency Act (“CTA”) while the Fifth Circuit continues to review a constitutional challenge to the law. Previously,...more

CTA – The Large Operating Company Exemption – Not Everybody Can Be A “Big BOI”

In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more

IRS Updates FATCA FAQs, Addresses January Temporary Regulations

On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act (“FATCA”) compliance page, which is available only online. These additional FAQs...more

Proposed FBAR Regulations Expand Filing Exemption and Reporting Requirements

As reported in our prior client alerts, the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), must be filed by a U.S. person that holds a financial interest in, or signature or other authority over, a...more

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