News & Analysis as of

Filing Deadlines National Security FinCEN

Troutman Pepper Locke

CTA Significantly Amended by Interim Final Rule

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On March 21, the Financial Crimes Enforcement Network (FinCEN) submitted an interim final rule (IFR) to the Federal Register, regarding the beneficial ownership information (BOI) reporting requirements under the Corporate...more

Verrill

NEED MORE COWBELL: FinCEN Not Satisfied with Current Deadlines and Requirements under the Corporate Transparency Act

Verrill on

On February 27, 2025, FinCEN issued a press release announcing future changes but giving no guidance about the scope of those changes: “No later than March 21, 2025, FinCEN intends to issue an interim final rule that...more

Kilpatrick

Corporate Transparency Act Back in Effect | New Beneficial Ownership Report Filing Deadline is March 21, 2025

Kilpatrick on

We previously reported that enforcement of the Corporate Transparency Act (CTA) was enjoined nationwide due to a preliminary injunction in the case of Smith v. U.S. Department of the Treasury....more

Wilson Sonsini Goodrich & Rosati

The Corporate Transparency Act is Back On–Again!

On February 18, 2025, the U.S. District Court for the Eastern District of Texas granted the federal government’s motion for a stay pending appeal and lifted the nationwide preliminary injunction in Smith, et al. v. U.S....more

Foley Hoag LLP

Corporate Transparency Act Revived After Last Remaining Nationwide Preliminary Injunction is Lifted - Reporting Deadlines Extended

Foley Hoag LLP on

On February 18, 2025, the U.S. Federal District Court for the Eastern District of Texas lifted the last remaining nationwide preliminary injunction of the CTA in the Smith case. This follows a decision on January 23, 2025, by...more

Ballard Spahr LLP

CTA Reporting Requirements Reinstated With March 21 Deadline for Most Reporting Companies

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As a result of a decision by the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Department of the Treasury on Tuesday, February 18, beneficial ownership information (BOI) reporting requirements under...more

Nelson Mullins Riley & Scarborough LLP

Corporate Transparency Act Reporting Obligations Reinstated; Deadline Extended 30 Days

On February 19, 2025, FinCEN released a statement that BOI reporting obligations under the CTA are back in effect, after a recent U.S. District Court decision in the ongoing case of Smith et al. v. U.S. Department of the...more

Parker Poe Adams & Bernstein LLP

Corporate Transparency Act Reporting Requirements Are Back: New March 21 Deadline

In the latest twist involving the Corporate Transparency Act (CTA), the only nationwide injunction still in effect that barred enforcement of the CTA’s filing deadlines (Smith vs. U.S. Department of the Treasury) was stayed...more

McGlinchey Stafford

CTA’s Beneficial Ownership Reporting Requirement Resumes – At Least for Now

McGlinchey Stafford on

As the saga of on-again-off-again requirements continues to unfold, FinCEN’s Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) have undergone significant changes due to...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: Injuction Lifted - Corporate Transparency Act Back in Effect

On February 17, a federal judge in Texas lifted a preliminary injunction issued in Smith v. United States Department of the Treasury, removing the last legal hurdle to the enforcement of the Corporate Transparency Act...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

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

Lewitt Hackman

Corporate Transparency Act Year-End Deadlines Rapidly Approaching

Lewitt Hackman on

As we previously communicated in a client compliance alert last November, the federal Corporate Transparency Act (the CTA went into effect on January 1, 2024) requires certain organizations including corporations, limited...more

Seyfarth Shaw LLP

Upcoming Deadline for Corporate Transparency Act Compliance

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As we near the end of 2024, it’s crucial to be aware of an important deadline under the Corporate Transparency Act (CTA). Reporting companies formed before January 1, 2024, must file their initial Beneficial Ownership...more

Pullman & Comley, LLC

The Corporate Transparency Act: End of Year Deadlines are Approaching - Why Compliance Is Crucial for Business Owners

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The Corporate Transparency Act (CTA), the federal initiative to limit money laundering, tax evasion, and other illicit activities, took effect on Jan. 1, 2024. The CTA requires many businesses and their owners to register...more

Lathrop GPM

Six-Step Quick Guide to the Beneficial Ownership Information (“BOI”) Reporting Rules of the Corporate Transparency Act (“CTA”)

Lathrop GPM on

In September 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the final beneficial ownership information (“BOI”) reporting rules (the “BOI Reporting Rules”) of the Corporate...more

Vorys, Sater, Seymour and Pease LLP

Get Ready for the CTA—The Deadline is Fast Approaching!

Over 30 million companies now have less than 70 days to file their initial reports under the new federal Corporate Transparency Act (CTA).  Here is the bottom line and why it matters. ...more

Torres Trade Law, PLLC

The Corporate Transparency Act: Treasury’s New Back Door for Finding CFIUS Non-Notified Transactions

Torres Trade Law, PLLC on

Much has been written about the Corporate Transparency Act (“CTA”), which was enacted on January 1, 2021, and went into effect on January 1, 2024. Briefly, the CTA requires “reporting companies” to disclose beneficial...more

Downs Rachlin Martin PLLC

Corporate Transparency Act - New Federal Reporting Requirement For Entities

Background - In January 2021, the United States Congress passed the Corporate Transparency Act (CTA) as part of the Anti-Money Laundering Act of 2020. This law, while intended to prevent criminal actors from hiding and...more

Venable LLP

Looming CTA Disclosure Requirements and Healthcare Providers

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The Federal Corporate Transparency Act (the CTA), 31 U.S.C. §5336, will soon require certain entities to disclose to the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) certain pieces of identifying information...more

Ballard Spahr LLP

CTA Round-Up: FinCEN Proposes Extended CTA Filing Deadline, Revised Reporting Form, and Privacy Act Exemption; Expands CTA FAQs;...

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The Financial Crimes Enforcement Network (“FinCEN”) has issued a flurry of publications relating to the Corporate Transparency Act (“CTA”).  They pertain, in part, to a proposed extension of the filing deadline for certain...more

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