News & Analysis as of

Administrative Procedure Act Reporting Requirements

Mitchell, Williams, Selig, Gates & Woodyard,...

Greenhouse Gas Reporting Rule for 2024 Data: Environmental Defense Fund Files Judicial Challenge to U.S. Environmental Protection...

The United States Environmental Protection Agency (“EPA”) extended on March 20th the reporting deadline under the Greenhouse Gas Reporting Rule for 2024 data. See 90 Fed. Reg. 13085. EPA extended the reporting deadline...more

Williams Mullen

Corporate Transparency Act Update: All Domestic Reporting Companies and U.S. Citizens Exempt from CTA

Williams Mullen on

In a release dated March 21, 2025, FinCEN announced an Interim Final Rule that significantly narrows the scope of the Corporate Transparency Act (the “CTA”). The Interim Final Rule goes into effect immediately when published...more

Sheppard Mullin Richter & Hampton LLP

CFPB Small Business Lending Data Rule Survives Challenge in Federal Court

On February 19, a federal magistrate judge for the United States District Court for the Southern District of Florida issued a report and recommendation rejecting a trade group’s challenge to the CFPB’s small business lending...more

Bass, Berry & Sims PLC

CTA Beneficial Ownership Information Reporting Requirements Resume March 21, 2025; Preliminary Injunctions Lifted

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On February 18, the U.S. District Court for the Eastern District of Texas lifted the preliminary injunction against enforcement of the Corporate Transparency Act (CTA) and the beneficial ownership reporting rule promulgated...more

Sheppard Mullin Richter & Hampton LLP

Texas Federal Court Pauses CFPB Rule Banning Medical Debt from Credit Reports

On February 6, a judge for the United District Court for the Eastern District of Texas issued a 90-day stay on the CFPB’s final rule prohibiting the inclusion of medical debt in consumer credit reports, delaying the rule’s...more

BCLP

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

BCLP on

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

DLA Piper

SEC Climate Disclosure Rules: Four Potential Paths Under President Trump

DLA Piper on

The US Securities and Exchange Commission (SEC) adopted landmark final rules (Climate Disclosure Rules, or Rules) in March 2024 intended to enhance and standardize climate-related disclosures for publicly listed companies....more

Seyfarth Shaw LLP

The New Administrative False Claims Act: Key Amendments and Implications

Seyfarth Shaw LLP on

On December 23, 2024, the Servicemember Quality of Life Improvement and National Defense Authorization Act (NDAA) for Fiscal Year 2025 (FY 2025 NDAA) (P.L. 118-159) was signed into law. Among its numerous provisions, the FY...more

Bass, Berry & Sims PLC

Supreme Court Enters the Corporate Transparency Act Fray, But Enforcement and Filings Remain on Hold

Bass, Berry & Sims PLC on

On January 23, the U.S. Supreme Court lifted the nationwide injunction entered by the federal district court in the Eastern District of Texas in the case styled Texas Top Cop Shop v. McHenry, which had barred enforcement of...more

Saul Ewing LLP

Corporate Transparency Act Reporting Requirements Still on Hold

Saul Ewing LLP on

The Corporate Transparency Act (CTA), enacted in 2021, mandates that companies disclose their true ownership to the Financial Crimes Enforcement Network (FinCEN) to combat illicit financial activities. However, its...more

King & Spalding

CTA Compliance Stay Continues Despite Supreme Court Lifting Nationwide Injunction; FinCEN Recognizes Separate District Court Stay...

King & Spalding on

On January 23, 2025, the U.S. Supreme Court granted the government’s motion to lift the nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in Texas Top Cop Shop v. McHenry (formerly, Texas Top...more

Williams Mullen

Corporate Transparency Act Update: Still Enjoined, Filings Still Voluntary, No Penalties for Not Filing

Williams Mullen on

Corporate Transparency Act (CTA) news in January and December 2024 has been plentiful. Here is the running recap of significant December and January events...more

Mayer Brown

Not Quite Yet: Supreme Court Stays CTA Injunction, But Filing Requirements Remain Suspended

Mayer Brown on

AT A GLANCE - The US Supreme Court has stayed the injunction against the Corporate Transparency Act (CTA), but the requirement for companies to file beneficial ownership information remains suspended, creating ongoing...more

Husch Blackwell LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act -

Husch Blackwell LLP on

As of the posting of this article, reporting companies nationwide do not need to comply with the Corporate Transparency Act’s (CTA) revised beneficial owner information (BOI) reporting deadlines, though the situation may...more

BCLP

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

BCLP on

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

Allen Matkins

Is This CARB Climate Corporate Data Accountability Act Enforcement Notice Legal?

Allen Matkins on

Recently, UCLA Professor Stephen Bainbridge posted this critique of California's climate disclosure laws - SB 253 and SB 261.  Readers of this blog will recall that SB 253 requires "reporting entities" to disclose Scope 1, 2...more

Bracewell LLP

The Trump Administration’s Day-One Executive Actions: Impacts on Energy and Environmental Policy and More

Bracewell LLP on

On January 20, 2025, President Trump re-assumed the presidency with a flurry of executive orders and memoranda, many of which directly impacted energy and environmental issues. These orders included a production-minded...more

Farella Braun + Martel LLP

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

Brownstein Hyatt Farber Schreck

The FTC Announces Increased HSR Thresholds for 2025

On Jan. 10, 2025, the Federal Trade Commission announced the 2025 adjusted thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (“HSR Act”). The HSR Act notification requirements apply to transactions...more

Baker Donelson

No More Lists – IRS Concedes on Reportable Transaction Penalties

Baker Donelson on

Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more

ArentFox Schiff

ESG Update: Four Reasons Why 2024 Should Be Remembered as ‘Transitional’ but Not ‘Transformational’ in the Environmental and...

ArentFox Schiff on

In the environmental space, 2024 has been a memorable year with regulatory efforts and court decisions touching on every aspect of environmental and energy regulation, capped out by a closely divided election....more

DarrowEverett LLP

Injunction Halts Enforcement of Corporate Transparency Act: What’s Next?

DarrowEverett LLP on

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 (CTA) and its reporting rule...more

Ballard Spahr LLP

Texas Judge Rules CFPB Did Not Exceed Authority in Issuing Small Business Reporting Rule

Ballard Spahr LLP on

In a tentative win for the CFPB, a federal judge in Texas ruled on August 26, 2024, that the agency did not exceed its authority when it issued its final Section 1071 small business lending rule. The court also rejected...more

Proskauer - Tax Talks

Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactions

Proskauer - Tax Talks on

On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term...more

Fox Rothschild LLP

IRS Issues Basis Shifting Guidance for Partnerships, Proposes Reporting Requirements

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The Internal Revenue Service (IRS) and U.S. Department of Treasury recently issued guidance to curtail what they consider abusive basis shifting by related-party partners and partnerships. That guidance, which was issued June...more

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