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Effective February 18, 2025, and until further notice, beneficial ownership information report filings under the Corporate Transparency Act are once again legally required. The deadline for most reporting companies to file...more
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
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
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
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
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
In yet another twist, the CTA is again currently enjoined (for now). On Dec. 26, in a highly unusual chain of events, the merits panel of the Fifth Circuit Court of Appeals vacated the emergency stay granted by the motions...more
On December 23, 2024, in Texas Top Cop Shop, Inc. v. Merrick Garland, Civil Action No.4:24-CV-478 (5th Cir. 2024), the Fifth Circuit Court of Appeals lifted a nationwide preliminary injunction and stay of the U.S. Corporate...more
High drama in Corporate Transparency Act (CTA) world: The latest saga involving the CTA commenced with the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., where a federal district court judge for the U.S....more
The Corporate Transparency Act (CTA), which went into effect on January 1, 2024, mandates that almost all LLC owners submit annual beneficial ownership reports (BOI) to the Financial Crimes Enforcement Network (FinCEN). ...more
As detailed in our prior client memo regarding Texas Top Cop Shop, Inc. v. Garland, the federal district court in the Eastern District of Texas (Sherman Division) issued an order for a nationwide preliminary injunction...more
As the government and interested parties continue to fight over the enforcement of the Corporate Transparency Act’s reporting requirements, prudent businesses and reporting companies should be prepared to comply with all...more
As previously reported, on December 5, 2024, the U.S. Department of Justice (DOJ), on behalf of the Department of Treasury, appealed a federal court preliminary injunction enjoining enforcement of the Corporate Transparency...more
The U.S. Department of Justice (DOJ) on Dec. 13, 2024, filed an emergency motion with the U.S. Court of Appeals for the Fifth Circuit to stay the nationwide preliminary injunction that was issued by the U.S. District Court...more
On Dec. 11, 2024, the U.S. government filed a motion requesting an immediate stay of the preliminary nationwide injunction issued last week by a federal district court in Texas that temporarily halted the implementation of...more
Entities should continue preparing to comply with BOI reporting requirements. On December 10, 2024, the Financial Crimes Enforcement Network (FinCEN) alerted businesses that, for now, they do not need to report their...more
On December 3, 2024, a Texas federal district court issued a preliminary injunction blocking enforcement of the Corporate Transparency Act (CTA). The Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) has...more
On December 3, 2024, the U.S. District Court for the Eastern District of Texas entered a preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA) and its implementation of regulations nationwide....more
As we previously discussed, on December 3, 2024, Judge Amos Mazzant of the U.S. District Court for the Eastern District of Texas issued a memorandum opinion and order granting a nationwide preliminary injunction against the...more
The U.S. District Court for the Eastern District of Texas on Dec. 3, 2024, issued a nationwide preliminary injunction suspending the government's enforcement of the Corporate Transparency Act (CTA) and its Implementing...more
On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against 31 U.S.C. § 5336 and the enforcement of the beneficial ownership information reporting rule...more
On December 6, 2024, the Financial Crimes Enforcement Network, a bureau of the U.S. Department of the Treasury (“FinCEN”), posted a statement on its website affirming that entities qualifying as “reporting company” (defined...more
On December 3, 2024, the federal district court in the Eastern District of Texas issued an order (Order) for a nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) in Texas Top Cop...more