News & Analysis as of

Filing Deadlines Constitutional Challenges Corporate Transparency Act

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

Perkins Coie

Corporate Transparency Act: FinCEN Releases Interim Rule Limiting Application of CTA to Foreign Companies Registered to Do...

Perkins Coie on

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

Kohrman Jackson & Krantz LLP

The Corporate Transparency Act Returns: What You Need to Know

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

Polsinelli

Important Update – Corporate Transparency Act Filing Obligations Reinstated and Mandatory

Polsinelli on

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

DLA Piper

CTA Update: Reporting Rule Reinstated; FinCEN Imposes March 21 Reporting Deadline for Most Reporting Companies

DLA Piper on

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

Eversheds Sutherland (US) LLP

And just like that—the Corporate Transparency Act is back!

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

Orrick, Herrington & Sutcliffe LLP

Corporate Transparency Act Beneficial Reporting Back in Effect – Stay Tuned

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

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

Wiley Rein LLP

Corporate Transparency Act Reinstated; New March Deadline for BOI Reports

Wiley Rein LLP on

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

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

PilieroMazza PLLC

Corporate Transparency Act, Part 8: Supreme Court Weighs In; Voluntary Reporting Remains

PilieroMazza PLLC on

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

Wilson Sonsini Goodrich & Rosati

On Again, Off Again – The Corporate Transparency Act is Off Again!

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

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

Hinshaw & Culbertson LLP

Yet Another Twist: Fifth Circuit Reinstates Nationwide Freeze on Enforcement of Corporate Transparency Act Filing Deadlines – What...

Hinshaw & Culbertson LLP on

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

Seyfarth Shaw LLP

Fifth Circuit Court Stays Nationwide Injunction on CTA Enforcement - BOI Reporting Requirements Resume

Seyfarth Shaw LLP on

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

Dickinson Wright

Fifth Circuit Reverses CTA Injunction, Deadline Extended

Dickinson Wright on

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

Hinshaw & Culbertson LLP

Fifth Circuit Overturns Preliminary Nationwide Injunction Against Corporate Transparency Act – FinCEN Announces Extension of...

Hinshaw & Culbertson LLP on

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

Pullman & Comley, LLC

Corporate Transparency Act Enforcement Resumes with Extended Deadlines: January 1, 2025 Deadline Extended to January 13, 2025

Pullman & Comley, LLC on

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

Fox Rothschild LLP

Federal Appeals Court Stays Nationwide Injunction of Corporate Transparency - Act #2

Fox Rothschild LLP on

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

Weintraub Tobin

Court Blocks Nationwide Injunction of the Corporate Transparency Act: Fifth Circuit Grants Stay Pending Appeal; Compliance Period...

Weintraub Tobin on

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

Neal, Gerber & Eisenberg LLP

5th Circuit Reinstates Corporate Transparency Act Filing Deadline; Treasury Department Grants Extension

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

Foster Garvey PC

Texas Court Halts Enforcement of the Corporate Transparency Act

Foster Garvey PC on

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

Venable LLP

Looming Reporting Deadline Under the Corporate Transparency Act: The Reality Sets In

Venable LLP on

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

Smith Anderson

The Corporate Transparency Act - Case Law Update and Determining Beneficial Owners

Smith Anderson on

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

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