News & Analysis as of

Filing Requirements U.S. Treasury Filing Deadlines

Foley Hoag LLP

BE-10 Benchmark Survey of U.S. Direct Investment Abroad – Filings Due May 30 or June 30, 2025

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Key Takeaways: - The U.S. Bureau of Economic Analysis (BEA) has announced that it is once again time to file the BE-10 Benchmark Survey of U.S. Direct Investment Abroad. The benchmark survey covers the universe of U.S....more

Pillsbury Winthrop Shaw Pittman LLP

CTA Deadline Approaching for Foreign Reporting Companies

The Corporate Transparency Act (CTA) was adopted by Congress in January 2021 and became effective on January 1, 2024. Under the CTA and the initial regulations implementing it, “reporting companies” (corporations, LLCs,...more

Husch Blackwell LLP

FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons Under the CTA

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule (IFR) removing the requirement for U.S. domestic reporting companies and U.S. persons to report Beneficial Ownership...more

Miller Canfield

UPDATED: FinCEN’s New Interim Final Rule (1) Exempts Domestic Companies from Corporate Transparency Act Reporting and (2) Sets New...

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a new interim final rule (new IFR) significantly limiting the scope of reporting required under the...more

Lowndes

On Again, Off Again: FinCEN's New Interim Final Rule on the Corporate Transparency Act – U.S. Entities and Citizens Exempt from...

Lowndes on

Anyone who has followed the on-again, off-again history of the Corporate Transparency Act’s (CTA) Beneficial Owner Information (BOI) reporting requirements will not be surprised that, effective March 26, the Financial Crimes...more

Stoel Rives LLP

Corporate Transparency Act – New Interim Final Rule

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The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule with respect to the Corporation Transparency Act (the “CTA”), exempting entities formed in the United States from the...more

Bodman

U.S. Companies and Business Owners Exempted from CTA Reporting Requirements

Bodman on

The Financial Crimes Enforcement Network (“FinCEN”) has issued an interim final rule that would exempt U.S. companies and U.S. persons from reporting their beneficial ownership information (“BOI”) as part of the Corporate...more

Bracewell LLP

FinCEN Adopts Interim Final Rule Limiting CTA Reporting Requirements to Foreign Reporting Companies

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US legal entities are no longer subject to the reporting requirements of the Corporate Transparency Act (CTA). On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of Treasury...more

Robinson & Cole LLP

Legal Update: New Rulemaking Announced: Treasury Department Suspends Reporting, Enforcement and Fines under the Corporate...

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How Did We Get Here? The Corporate Transparency Act (CTA) went into effect on January 1, 2024, and was enacted as part of the Anti-Money Laundering Act of 2020....more

Clark Hill PLC

CTA Reporting and Enforcement Suspended Indefinitely

Clark Hill PLC on

In a whirlwind series of announcements, the Treasury Department and FinCEN have suspended all Corporate Transparency Act (CTA) reporting and enforcement for domestic entities indefinitely. On Feb. 27, FinCEN announced that...more

Saul Ewing LLP

U.S. Treasury Announces It Will Not Enforce the Corporate Transparency Act Against U.S. Companies and Citizens

Saul Ewing LLP on

​On March 1, 2025, the U.S. Department of the Treasury announced that it will not enforce the Corporate Transparency Act (CTA) against U.S. citizens or domestic reporting companies or their beneficial owners. Treasury also...more

Dickinson Wright

U.S. Treasury Department Suspends Enforcement of Corporate Transparency Act for U.S. Citizens and U.S. Companies

Dickinson Wright on

The U.S. Department of the Treasury announced on March 2, 2025 that it will not take any enforcement action against U.S. citizens and legal entities formed in the United States or their beneficial owners in connection with...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

CTA Beneficial Reporting Filing Obligations for Domestic Reporting Companies—Gone For Good?

Stop us if you have heard this before, but there has been yet another development in the saga that is the Corporate Transparency Act (“CTA”). Following a recent ruling from the U.S. District Court for the Eastern District of...more

Polsinelli

Important Update – Treasury Will Not Enforce CTA Against U.S. Citizens, Domestic Reporting Companies and Their Beneficial Owners –...

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The U.S. Department of the Treasury announced on Sunday March 2, 2025 that it will “not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners [ …]” This press release...more

Cadwalader, Wickersham & Taft LLP

U.S. Treasury Department Suspends Enforcement of Corporate Transparency Act Against Domestic Reporting Companies and U.S....

On March 2, 2025, the U.S. Treasury Department announced it will not enforce any penalties or fines against U.S. citizens, domestic reporting companies, or beneficial owners of domestic reporting companies under the Corporate...more

Hinshaw & Culbertson LLP

UPDATE: U.S. Department of the Treasury Terminates Enforcement of the Corporate Transparency Act Against U.S. Citizens and...

U.S. citizens and domestic companies will no longer be subject to the CTA or its reporting requirements. Just under two weeks after the Financial Crimes Enforcement Network (FinCEN), an enforcement bureau within the U.S....more

Stinson LLP

CTA Effectively Paused: No Enforcement Actions Until FinCEN Issues New Interim Final Rule and Revised Reporting Deadlines

Stinson LLP on

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury announced that it will not be issuing any fines or penalties or taking any other enforcement actions against any...more

Burr & Forman

Corporate Transparency Act Enforcement Suspended for U.S. Citizens and U.S. Entities

Burr & Forman on

What Happened? On February 18, 2025, the last of the nationwide injunctions enjoining enforcement of the Corporate Transparency Act (“CTA”), Smith, et al. v. U.S. Department of the Treasury, et al., (E.D. Tex.), was stayed,...more

Bilzin Sumberg

Treasury Department and FinCEN Announce Drastic Limits on Enforcement of Corporate Transparency Act

Bilzin Sumberg on

In a March 2, 2025 press release, the US Treasury Department announced that not only will it not enforce any penalties or fines associated with the beneficial ownership information (BOI) reporting rule under the existing...more

Lowndes

Corporate Transparency Act Will Not Be Enforced Against U.S. Citizens and Entities

Lowndes on

In a press release issued on March 2, 2025, the United States Department of the Treasury announced that “with respect to the Corporate Transparency Act…[it will] not enforce any penalties or fines against U.S. citizens or...more

Wyrick Robbins Yates & Ponton LLP

Treasury Department Suspends Enforcement of Corporate Transparency Act for U.S. Citizens and Domestic Reporting Companies

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that it would not issue any fines or penalties or take any other enforcement actions against any companies based on a failure to file or...more

Morris, Manning & Martin, LLP

Treasury Department Ends its Enforcement of CTA, But Compliance Risks Remain

On March 2, 2025, the U.S. Treasury Department issued a press release announcing that, for now, the Department will not enforce any penalties or fines associated with the beneficial ownership information reporting rule under...more

Winstead PC

Corporate Transparency Act Update: Reporting Requirements Now Back in Effect

Winstead PC on

Beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are now back in effect. As a result, all entities subject to the CTA are once again obligated to file BOI reports with...more

Stinson LLP

Second CTA Nationwide Injunction Stayed; New March 21, 2025 Filing Deadline

Stinson LLP on

On January 23, 2025, the U.S. Supreme Court granted the government’s motion to stay a nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (CTA) issued by a federal judge in Texas (Texas...more

Spilman Thomas & Battle, PLLC

Court Lifts Injunction on Corporate Transparency Act – Most Companies Must File by March 21, 2025

After months of litigation, the Corporate Transparency Act (“CTA”) is once again effective, and most companies subject to the CTA are required to file Beneficial Ownership Information (“BOI”) reports with the U.S. Treasury’s...more

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