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As of February 18, 2025, the US Department of the Treasury Financial Crimes Enforcement Network’s (FinCEN) Corporate Transparency Act (CTA) reporting requirements have been restored—at least temporarily. The new filing...more
As of the posting of this article, reporting companies nationwide once again need to comply with the Corporate Transparency Act’s (CTA) revised beneficial owner information (BOI) reporting deadlines. FinCEN has set the...more
As we previously discussed, on January 7, 2025, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction delaying the implementation of the Corporate Transparency Act’s (“CTA”) reporting...more
On February 18, a federal court lifted the remaining injunction blocking enforcement of the Corporate Transparency Act (“CTA”), previously discussed. In response, FinCEN has stated that the reporting deadline for existing...more
The Corporate Transparency Act’s reporting obligations are once again in force. For virtually all reporting companies, the new deadline to file an initial, updated and/or corrected beneficial ownership information (BOI)...more
On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed the nationwide injunction it previously issued in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (Smith case)....more
In the latest in a series of back-and-forth developments, the Corporate Transparency Act (CTA) is once again enforceable following a federal district court decision, with the Financial Crimes Enforcement Network (FinCEN)...more
The Corporate Transparency Act (CTA) is back in effect − at least for now − and companies covered by the CTA are once again required to file beneficial ownership information (BOI) reports with FinCEN. On February 17, 2025, in...more
On February 18, 2025, U.S. District Judge Jeremy Kernodle of the Eastern District of Texas stayed his prior injunction against enforcement of the Corporate Transparency Act (the “CTA”) pending appeal by the U.S. Department of...more
In our last update, we reported that despite the Supreme Court staying the nationwide injunction against FinCEN’s enforcement of the CTA in one Texas case, a nationwide stay of the Reporting Rule granted by a federal judge in...more
In the latest twist involving the Corporate Transparency Act (CTA), the only nationwide injunction still in effect that barred enforcement of the CTA’s filing deadlines (Smith vs. U.S. Department of the Treasury) was stayed...more
On Feb. 17, the Texas federal district court in Smith v. U.S. Department of the Treasury granted the government’s motion for an immediate stay pending appeal of the nationwide order staying the effective date of the final...more
As discussed last month, in early January, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction temporarily blocking enforcement of the Corporate Transparency Act (CTA) (see Smith et al....more
The Corporate Transparency Act (CTA) remains on hold due to a nationwide injunction granted by a federal District Court in Texas in Smith v. U.S. Department of the Treasury. However, given pending legal battles and...more
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
While the United States Supreme Court recently lifted one nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in the case of Texas Top Cop Shop, Incorporated et al. v. McHenry (formerly Garland),...more
On Feb. 5, the U.S. government filed (i) a notice of appeal of the order issued Jan. 7 by a U.S. District Court in Texas in Smith v. U.S. Department of Treasury, No. 6:24-cv-336-JDK (E.D. Tex. Jan. 7, 2025), which had issued...more
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
(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
On February 5, 2025, the United States filed a motion in the case of Samantha Smith, et al., v. United States Department of Treasury, et al., to stay the order of the Federal District Court for the Eastern District of Texas,...more
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
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
Considering conflicting rulings, businesses remain understandably confused about whether to file their mandated Beneficial Ownership Reports with FinCen. As of this writing, the answer remains that businesses may file but are...more
On January 23, 2025, the Supreme Court of the United States granted the federal government’s motion to stay the nationwide injunction preventing enforcement of the Corporate Transparency Act (the “CTA”) entered by the United...more
On Thursday, January 23, 2025, in an 8-1 decision, the U.S. Supreme Court stayed one of the two nationwide injunctions of the Corporate Transparency Act (CTA) pending the conclusion of the Fifth Circuit appeal and any...more