News & Analysis as of

Corporate Transparency Act Filing Requirements Constitutional Challenges

McNees Wallace & Nurick LLC

Closing Call for the Corporate Transparency Act: FinCEN Removes Reporting Requirements for Domestic Business Entities

After almost fifteen months of legal challenges, conflicting court rulings, changing guidance from the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN), and a general air of uncertainty, it appears...more

Cozen O'Connor

FinCEN Exempts US Entities and Persons from CTA

Cozen O'Connor on

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) adopted an interim final rule (Rule) exempting U.S. companies previously subject to the reporting requirements under the Corporate Transparency Act (CTA)...more

Cozen O'Connor

FinCEN Pauses Enforcement Actions under CTA

Cozen O'Connor on

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not take enforcement actions against any companies for failure to file or update beneficial ownership information (BOI) reports...more

Lowndes

Return of the CTA – FinCEN Once Again Able to Enforce Filing Requirements

Lowndes on

The beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are back in effect. The CTA generally requires “reporting companies” (any domestic or foreign entity registered...more

Bodman

The Saga Continues: CTA Requirements are Back in Effect

Bodman on

A Texas federal judge has ordered a stay of a nationwide injunction that placed the Corporate Transparency Act’s (“CTA”) filing requirements on hold. As a result, the CTA’s reporting requirements are back in effect. FinCEN...more

Hinshaw & Culbertson LLP

URGENT UPDATE: Corporate Transparency Act Reporting Requirements Back in Effect – What You Need To Know

Companies are once again required to comply with the CTA and its reporting obligations. As discussed in our previous update, last month the Supreme Court of the United States (SCOTUS) stayed (i.e., suspended the effect of)...more

Shipman & Goodwin LLP

Whiplash Redux - The Corporate Transparency Act is Back

Shipman & Goodwin LLP on

The preliminary injunction in Smith, et al. v. U.S. Department of the Treasury that was still pausing any required filings by reporting companies under the Corporate Transparency Act (CTA) was lifted on February 17, 2025 by...more

Pierce Atwood LLP

It Lives: Trump Administration Defends Corporate Transparency Act; May Modify its Application

Pierce Atwood LLP on

On February 5, 2025, the Trump administration added a new chapter to the saga that has been implementation of the Corporate Transparency Act (CTA), filing a notice of appeal and motion for stay against an Eastern District of...more

Flaster Greenberg PC

Corporate Transparency Act Updates

Flaster Greenberg PC on

(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

Flaster Greenberg PC

Corporate Transparency Act Update As of January 23, 2025

Flaster Greenberg PC on

Despite a Supreme Court ruling on January 23, there have been no material changes regarding Corporate Transparency Act (“CTA”) filing obligations. As of January 23, current FinCEN guidance is that no entity is required to...more

Warner Norcross + Judd

CTA Filing Obligations Remain Voluntary Amid Court Challenges

Warner Norcross + Judd on

After a few days on a legal roller coaster, enforcement and reporting obligations under the Corporate Transparency Act (CTA) remain on hold as lawsuits challenging the CTA’s constitutionality continue. On Jan. 23, 2025, the...more

Verrill

Status of CTA Reporting Rule as of January 24, 2025

Verrill on

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

Foley Hoag LLP

Corporate Transparency Act Remains Subject to Nationwide Preliminary Injunction Despite Supreme Court Ruling

Foley Hoag LLP on

On January 23, 2025, the U.S. Supreme Court stayed a nationwide preliminary injunction of the Corporate Transparency Act (“CTA”) previously issued by the U.S. Federal District Court for the Eastern District of Texas (Texas...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

McCarter & English, LLP

The Evolution of the CTA: BOIR Filing Still Voluntary (For Now)

Jaunary 23, the US Supreme Court (SCOTUS) issued a highly anticipated decision with respect to the reporting requirements and enforcement of the Corporate Transparency Act (31 U.S.C. § 5336, the CTA). As summarized below, a...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

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

Kilpatrick

Corporate Transparency Act Still Enjoined Despite Recent Supreme Court Ruling

Kilpatrick on

We previously reported that on December 26, 2024, a panel of the United States Court of Appeals for the Fifth Circuit restored the nationwide preliminary injunction against enforcement of the federal Corporate Transparency...more

Woods Rogers

Corporate Transparency Act Subject to Nationwide Injunction (Again)

Woods Rogers on

The on-again, off-again nationwide injunction barring enforcement of the Corporate Transparency Act (CTA) is back on. The Fifth Circuit Court of Appeals will hear the case of Texas Top Cop Shop, Inc. v. Merrick Garland,...more

Warner Norcross + Judd

CTA Reporting Obligations Again Suspended

Warner Norcross + Judd on

Our roller coaster ride with the Corporate Transparency Act (CTA) continues. On Dec. 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated its Dec. 23 order staying the prior injunction in Texas Top Cop Shop, Inc....more

DarrowEverett LLP

After Corporate Transparency Act Takes Hit in Ruling, What's Next?

DarrowEverett LLP on

The Corporate Transparency Act (“CTA”), a significant legislative effort aimed at curbing financial crimes by increasing corporate accountability, has been declared unconstitutional by the U.S. District Court for the Northern...more

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