News & Analysis as of

Constitutional Challenges Reporting Requirements Appeals

Wilson Sonsini Goodrich & Rosati

SEC Votes to End Defense of Climate Disclosure Rules

On March 27, 2025, the SEC announced that it voted (2-1) to end its defense of the final enhanced and standardized climate-related disclosure rules (the Climate Rules). The SEC previously adopted the Climate Rules on March 6,...more

Vinson & Elkins LLP

Federal Climate Change Disclosures No More

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In a move that perhaps comes as no surprise, on March 27, 2025, the Securities and Exchange Commission (“SEC” or “the Commission”) issued Press Release 2025-58 announcing it had voted to end its defense of its climate-related...more

White & Case LLP

US Supreme Court Rejects Application of Commingling Theory in Holocaust Expropriation Case

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On February 21, 2025, the US Supreme Court issued a unanimous decision in Republic of Hungary v. Simon, further narrowing the scope of the Foreign Sovereign Immunities Act's exception to sovereign immunity for expropriation...more

McCarter & English, LLP

The Evolution of the CTA: Beneficial Ownership Information Reports Are Due by March 21, 2025

As of February 18, 2025, the US Department of the Treasury Financial Crimes Enforcement Network’s (FinCEN) Corporate Transparency Act (CTA) reporting requirements have been restored—at least temporarily. The new filing...more

Husch Blackwell LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act - UPDATED February 21,2025

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As of the posting of this article, reporting companies nationwide once again need to comply with the Corporate Transparency Act’s (CTA) revised beneficial owner information (BOI) reporting deadlines. FinCEN has set the...more

Cooley LLP

Corporate Transparency Act Reporting Requirements Reinstated With Deadline Extension

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In the latest in a series of back-and-forth developments, the Corporate Transparency Act (CTA) is once again enforceable following a federal district court decision, with the Financial Crimes Enforcement Network (FinCEN)...more

Wiley Rein LLP

Corporate Transparency Act Reinstated; New March Deadline for BOI Reports

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As discussed last month, in early January, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction temporarily blocking enforcement of the Corporate Transparency Act (CTA) (see Smith et al....more

Holland & Knight LLP

Corporate Transparency Act: Government Appeals Smith Case, Seeks Reporting Rule Reinstatement

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Here are the latest developments in the ongoing Corporate Transparency Act (CTA) saga...more

Womble Bond Dickinson

Corporate Transparency Act Compliance Still on Hold, For Now

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On January 23, the U.S. Supreme Court lifted a nationwide preliminary injunction on the enforcement of the Corporate Transparency Act (the CTA), a law requiring millions of business entities to report information about their...more

Flaster Greenberg PC

Corporate Transparency Act Updates

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(2/6/25) Update as of February 5, 2025: The government appealed the nationwide injunction blocking CTA enforcement in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.). FinCEN updated its...more

McGlinchey Stafford

FinCEN Commits to Extend CTA Reporting for 30 Days If Court Grants Stay of Injunction

McGlinchey Stafford on

On February 5, 2025, the United States filed a motion in the case of Samantha Smith, et al., v. United States Department of Treasury, et al., to stay the order of the Federal District Court for the Eastern District of Texas,...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

IR Global

Beneficial Ownership Reporting – To File or Not to File?

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Considering conflicting rulings, businesses remain understandably confused about whether to file their mandated Beneficial Ownership Reports with FinCen. As of this writing, the answer remains that businesses may file but are...more

Clark Hill PLC

CTA Litigation Update: Reporting Remains Voluntary

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On Jan. 23, the U.S. Supreme Court stayed the Dec. 5 nationwide injunction in Texas Top Cop Shop, Inc. v. Garland (E.D. Tex.) that had halted Corporate Transparency Act (“CTA”) enforcement nationwide. The stay of this...more

King & Spalding

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

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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

Holland & Knight LLP

Supreme Court Stays CTA Injunction in Texas Top Cop Shop Case, but CTA Reporting Still on Hold

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In the Texas Top Cop Shop case, the U.S. District Court for the Eastern District of Texas on Dec. 3, 2024, issued an injunction that deferred all reporting requirements under the Corporate Transparency Act (CTA). (See Holland...more

Morris, Manning & Martin, LLP

Supreme Court Intervenes in CTA Legal Battle, But Implementation Still on Hold Due to Separate Injunction

The Supreme Court has weighed in on the ongoing battle concerning the Corporate Transparency Act (the CTA). As we previously wrote, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a...more

Cadwalader, Wickersham & Taft LLP

Corporate Transparency Act Remains on Hold Despite SCOTUS Stay of Injunction

On January 23, 2024, the Supreme Court overturned a nationwide injunction enjoining enforcement of the Corporate Transparency Act (“CTA”).  However, the implementing regulations of the CTA remain unenforceable due to a...more

Verrill

Status of CTA Reporting Rule as of January 24, 2025

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FinCEN announced on January 24: In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to...more

Moore & Van Allen PLLC

Corporate Transparency Act Reporting Obligations Remain Paused Despite Supreme Court Order

Moore & Van Allen PLLC on

On January 23, 2025, the United States Supreme Court ruled on McHenry v. Texas Top Cop Shop, Inc., granting the Government’s application to stay the injunction of the Corporate Transparency Act (“CTA”) initially ordered by...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

Cole Schotz

CTA Update: Companies Not Required To File Under The CTA, Despite Supreme Court Stay

Cole Schotz on

Despite a Supreme Court order issued on January 23, 2025, as of January 24, 2025, FinCEN has stated they are not requiring companies to file under the CTA. On January 23, 2025, the U.S. Supreme Court, in an unsigned order,...more

Wiley Rein LLP

CTA Update: Supreme Court Temporarily Lifts Injunction, but Requirements Remain Blocked

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On January 23, 2025, the U.S. Supreme Court issued a ruling that appears to settle – for now – a nearly two-month-long legal battle over the Corporate Transparency Act (CTA), which began with a nationwide preliminary...more

Rivkin Radler LLP

SCOTUS Hands Down CTA Decision — FinCEN Says Reporting Requirements Remain on Pause

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The Financial Crimes Enforcement Network (“FinCEN”) announced on Friday, January 24, 2025, that reporting companies are not currently required to file beneficial ownership information (“BOI”) under the Corporate Transparency...more

Proskauer Rose LLP

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

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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

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