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

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

Filing Obligations Reimposed!! Status of CTA Reporting Rule as of February 19, 2025

Updated February 20, 2025. The CTA seesaw continues. On February 19, FinCEN announced it is reinstating the CTA reporting obligations and setting new deadlines for submissions. Says FinCEN: “For the vast majority of...more

CTA Filing Obligations Have Been Reinstated—January 1, 2025 Deadline Pushed to January 13 for Most

On December 3, 2024, a US District Court in Texas ruled the Corporate Transparency Act unconstitutional and issued a nationwide preliminary injunction against its enforcement. That ruling was promptly appealed, and on...more

CTA Filing Deadlines Suspended (For Now)

You perhaps have heard the news that a US District Court in Texas ruled the Corporate Transparency Act unconstitutional and issued a nationwide preliminary injunction against its enforcement. In all, four US District Courts...more

Mid-year assessment: Are you in good shape on CTA compliance?

The Corporate Transparency Act (CTA) will require most privately-owned entities to file Beneficial Ownership Information (BOI) reports with FinCEN no later than January 1, 2025. The purpose of this Client Alert is to check in...more

Corporate Transparency Act—Overview and Initial Steps to Be Taken

The Corporate Transparency Act became effective January 1, 2024 and will require more than 30 million U.S. entities to register in 2024 with FinCEN (a bureau of the U.S. Treasury Department). Most large companies and...more

Who Must Be Reported as Beneficial Owners of a Reporting Company? - Update

The article was orginially posted on November 28, 2023 and has been updated to reflect changes that took effect in 2024. During 2024 the Corporate Transparency Act (CTA) and related CTA Rule will require an estimated 32.6...more

Corporate Transparency Act—Considerations Affecting Entities That Are Exempt or Excluded from Reporting Company Status - Update

This article was originally posted on November 30, 2023 and has been updated to reflect changes that went into effect in 2024. The Corporate Transparency Act (CTA) took effect on January 1, 2024. The Act is administered by...more

Determining Whether Your Entity is a Reporting Company: Selected Issues - Update

The article was originally posted on November 29, 2023 and has been updated to reflect changes that went into effect in 2024. Under the Corporate Transparency Act (CTA), more than 30 million “Reporting Companies” will...more

Corporate Transparency Act—Considerations Affecting Entities That Are Exempt or Excluded from Reporting Company Status

The Corporate Transparency Act (CTA) takes effect starting January 1, 2024. The Act is administered by FinCEN, a bureau of U.S. Treasury charged with combatting money laundering and other financial crimes. The central feature...more

No Longer a Walk in The Park - Entity Formation Under the Corporate Transparency Act (Updated)

Presently, forming a corporation, LLC or other entity in the U.S. can be done on a largely anonymous basis, without naming its owners and with only limited disclosures about managers, officers and directors. Under the...more

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