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FinCEN Eases CTA Reporting Rules: U.S. Companies Get a Pass, Foreign Entities Get a Breather

As previewed by FinCEN and Treasury earlier this month, FinCEN announced major changes to the application of the Corporate Transparency Act. On Friday evening, FinCEN issued an interim final rule that will remove the...more

Treasury Suspends CTA Enforcement Against U.S. Citizens and Companies; Federal District Court Declares CTA Unconstitutional

The Corporate Transparency Act (the “CTA”) remains in full force and effect, although FinCEN recently announced that it will not take any enforcement actions against reporting companies who fail either to file or to update...more

Pause for Effect: Current Corporate Transparency Act Deadlines will not be Enforced

Although the Corporate Transparency Act (the “CTA”) remains in full force and effect and, along with it, a requirement for most reporting companies to file their beneficial ownership information reports, the previously...more

Corporate Transparency Act Update: FinCEN Asks SCOTUS to Intervene

As previously reported, on December 26, 2024, the Fifth Circuit first lifted—and then reinstated—a preliminary nationwide injunction staying the Corporate Transparency Act’s (“CTA”) reporting requirements pending appeal....more

To File, or Not to File: the Fifth Circuit’s Evolving Treatment of the Corporate Transparency Act

The U.S. Court of Appeals for the Fifth Circuit reinstated and then subsequently suspended the reporting requirements under the Corporate Transparency Act (the “CTA”) over the course of the last week by staying the original...more

Gone but Not Forgotten: New FinCEN Guidance on CTA Reporting Requirements for Companies that Cease to Exist

FinCEN clarifies that entities that are dissolved in 2024, or merge into other entities in 2024, do still have beneficial ownership information filing requirements if not exempt....more

FinCEN Updates CTA FAQs for the First Time in Three Months - Includes Clarity About Reporting Requirements for Beneficial Owners

On April 18, 2024, the Financial Crimes Enforcement Network (FinCEN) published an updated set of Frequently Asked Questions (FAQs) pertaining to the Beneficial Ownership Information (BOI) Reporting Rule under the Corporate...more

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