News & Analysis as of

Filing Requirements Appeals Regulatory Requirements

WilmerHale

Corporate Transparency Act: It’s Still Paused (For Now)

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Entities subject to the Corporate Transparency Act’s beneficial ownership information reporting requirement are not currently required to file BOI reports. Beyond that, much remains in flux regarding whether and when...more

Neal, Gerber & Eisenberg LLP

DOJ Seeks to Reinstate Corporate Transparency Act

On February 5, 2025, the Department of Justice (DOJ) filed a notice of appeal and motion for stay of the injunction against enforcement of the Corporate Transparency Act (CTA) issued by the Eastern District of Texas in Smith...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

Spilman Thomas & Battle, PLLC

Corporate Transparency Act Still Blocked Despite Supreme Court Decision

The saga of confusing Corporate Transparency Act (CTA) litigation continues, but the guidance remains the same: companies are not currently obligated to file Beneficial Ownership Information (BOI) reports with the U.S....more

Hogan Lovells

CTA Required Reporting Still on Hold: Recent Supreme Court ruling affects one CTA beneficial ownership case, but other case...

Hogan Lovells on

Key takeaways TLDR: No mandatory BOI/CTA filing yet, but stay tuned pending resolution of a second case and subsequent FinCEN guidance. On January 23, 2025, the Supreme Court of the United States stayed the nationwide...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

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

Wyrick Robbins Yates & Ponton LLP

Corporate Transparency Act Remains Blocked Despite Supreme Court Order

Enforcement of the Corporate Transparency Act (the “CTA”) had been on hold since a December 26, 2024 ruling from the United States Court of Appeals for the Fifth Circuit in the case of Texas Top Cop Shop, Inc., et al. v....more

Ruder Ware

The CTA Journey – It Goes On and On and On

Ruder Ware on

The Corporate Transparency Act (“CTA”) has been on a journey this past month with a whirlwind of court rulings: halted by a federal district court, reinstated by the Fifth Circuit’s motions panel, had its reporting deadlines...more

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Court of Appeals Vacates Its Own Stay Rendering the Corporate Transparency Act Unenforceable . . . Again

On December 26, 2024, in Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, 2024 WL 5224138 (5th Cir. Dec. 26, 2024), a merits panel of the United States Court of Appeals for the Fifth Circuit issued an order vacating the...more

Sullivan & Worcester

Breaking: Corporate Transparency Act on Hold Again

Sullivan & Worcester on

Late on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed its own decision from earlier in the week, reinstating the nationwide preliminary injunction preventing the enforcement of the Corporate...more

UB Greensfelder LLP

Fifth Circuit Court of Appeals Reinstates Nationwide Injunction Blocking Enforcement of the Corporate Transparency Act

UB Greensfelder LLP on

On December 26, 2024, the Fifth Circuit Court of Appeals reinstated the nationwide preliminary injunction blocking enforcement of the Corporate Transparency Act (CTA). This decision was made to "preserve the constitutional...more

Parker Poe Adams & Bernstein LLP

Corporate Transparency Act Filings Are Back on Hold

In an unusual turn of events, the Fifth Circuit Court of Appeals has reversed itself and put the Corporate Transparency Act (CTA) back on hold....more

Eversheds Sutherland (US) LLP

Fifth Circuit changes course—CTA preliminary injunction reinstated

On December 26, 2024, the US Court of Appeals for the Fifth Circuit changed course, effectively reinstating the preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA)....more

Perkins Coie

Corporate Transparency Act: Court Swiftly Reimposes Injunction Against Enforcement

Perkins Coie on

As reported in our recent Update, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the...more

Benesch

On Hold AGAIN - CTA Preliminary Injunction Reinstated

Benesch on

As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction blocking the U.S. Department of Treasury from enforcing the Corporate...more

Miller Canfield

Fifth Circuit Reinstates Texas Federal District Court’s Nationwide Preliminary Injunction and Stay of the Corporate Transparency...

Miller Canfield on

Late in the day on December 26, 2024, the United States Court of Appeals for the Fifth Circuit reinstated a nationwide injunction staying enforcement of the Corporate Transparency Act (CTA) and its reporting rules and...more

Holland & Knight LLP

Corporate Transparency Act: Nationwide Injunction in Place Again; All Filing Deadlines Suspended

Holland & Knight LLP on

In a continuing series of dizzying judicial actions, the U.S. Court of Appeals for the Fifth Circuit on Dec. 26, 2024, vacated the stay and reinstated the nationwide preliminary injunction enjoining enforcement of the...more

Venable LLP

Fifth Circuit Reimposes Nationwide Preliminary Injunction

Venable LLP on

After a rollercoaster ride last week, the Corporate Transparency Act's (CTA) nationwide preliminary injunction remains in place for the immediate future, pending further review by the U.S. Court of Appeals for the Fifth...more

Foley Hoag LLP

Fifth Circuit Reinstates Nationwide Preliminary Injunction that Enjoined Reporting and Enforcement Under The Corporate...

Foley Hoag LLP on

In a highly unusual and unexpected order, late on December 26, 2024, a “merits panel” of the Fifth Circuit (made up of different judges than the “motions panel” that stayed the nationwide preliminary injunction on December...more

Spilman Thomas & Battle, PLLC

Corporate Transparency Act Nationwide Injunction Reinstated

If you are feeling a bit of whiplash today, you are not alone. The United States Court of Appeals for the Fifth Circuit has reinstated a preliminary nationwide injunction of the Corporate Transparency Act (“CTA”)....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

Skadden, Arps, Slate, Meagher & Flom LLP

Fifth Circuit Merits Panel Vacates Motions Panel’s Stay of Nationwide Injunction of Corporate Transparency Act

On December 26, 2024, the Fifth Circuit merits panel assigned to Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, reinstated a nationwide preliminary injunction enjoining enforcement of the Corporation Transparency Act and...more

Tucker Arensberg, P.C.

UPDATE: Corporate Transparency Act  (“CTA”) Enforcement Once Again On Hold

Tucker Arensberg, P.C. on

As of December 26, 2024, the nationwide injunction that had been lifted only days ago has been put back in effect. This means that reporting requirements under the Corporate Transparency Act may not be enforced for the time...more

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