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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
On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published the text of an interim rule formally revising the Corporate Transparency Act’s (CTA) definition of “reporting...more
Beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect. In the latest in a line of dizzying decisions surrounding the CTA, in Smith v. U.S....more
CTA filings are obligatory again. Most reporting companies have until March 21, 2025 to complete their filings. If you adopted a wait-and-see posture in regard to making your CTA BOIR filings, the wait is unfortunately over....more
On February 17, 2025, the US District Court for the Eastern District of Texas stayed its previous order suspending enforcement of the Corporate Transparency Act (CTA)’s Reporting Rule in Smith v. US Dept. of the Treasury,...more
The final judicial barrier to the Financial Crimes Enforcement Network’s enforcement of the Corporate Transparency Act’s beneficial ownership information (BOI) reporting requirements has been lifted. The Corporate...more
The Corporate Transparency Act (CTA) is back in effect − at least for now − and companies covered by the CTA are once again required to file beneficial ownership information (BOI) reports with FinCEN. On February 17, 2025, in...more
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
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
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
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
On January 23, 2025, the U.S. Supreme Court stayed the preliminary injunction issued by the U.S. District Court for the Eastern District of Texas in Texas Top Cop Shop, Inc., which halted reporting under the Corporate...more
On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated its previous order granting a stay of the nationwide preliminary injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 24-40792...more
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
Seventy-two hours after a motions panel of the U.S. Court of Appeals for the Fifth Circuit stayed the effect of a nationwide preliminary injunction imposed by a Texas federal district court blocking the reporting deadline for...more
On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit issued an order temporarily staying the nationwide preliminary injunction previously granted in Texas Top Cop Shop, Inc., et al. v. Garland, et al. While...more
On December 23, 2024, the Fifth Circuit Court of Appeals issued an Order which granted a stay of a lower court’s nationwide injunction against enforcement of the Corporate Transparency Act (CTA or the Act). Texas Top Cop...more
On December 23, 2024, a panel of the U.S. Court of Appeals for the Fifth Circuit lifted the preliminary injunction recently imposed by a Texas district court that had blocked the reporting deadline for filing Beneficial...more
On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the previously issued nationwide injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., which had the effect of reinstating...more
An appellate panel has stayed the nationwide injunction issued by a federal judge in Texas that halted enforcement of the Corporate Transparency Act (CTA). Hours later, the U.S. Financial Crimes Enforcement Network (FinCEN)...more
On December 23, 2024, the Fifth Circuit Court of Appeals granted the government’s emergency motion for a stay, effectively blocking a nationwide injunction issued by a district court against the Corporate Transparency Act...more
On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit entered an order that has the effect of reinstating Corporate Transparency Act (CTA) filing deadlines, including the upcoming deadline for certain entities...more
On December 3, 2024, U.S. District Judge Amos Mazzant of the Eastern District of Texas preliminarily enjoined the Corporate Transparency Act (“CTA”), 31 U.S.C. § 5336, nationwide and stayed the reporting deadline of January...more
Over three years ago, Congress enacted the federal Corporate Transparency Act ("CTA"), which for the first time obligates business owners, among others, to file beneficial ownership information ("BOI") reports with the U.S....more
As discussed in our prior two alerts (found here), effective as of Jan. 1, 2024, the Corporate Transparency Act and rules issued thereunder by the Financial Crimes Enforcement Network (“FinCEN”) (collectively, the “CTA”)...more