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UPDATE 2/26/25: There continue to be developments regarding the Corporate Transparency Act ("CTA") and the applicability of related filing obligations. Please note the following recent updates...more
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
The Corporate Transparency Act (CTA), enacted in 2021, mandates that companies disclose their true ownership to the Financial Crimes Enforcement Network (FinCEN) to combat illicit financial activities. However, its...more
On February 18, 2025, the U.S. District Court for the Eastern District of Texas (EDTX) lifted the nationwide injunction to the Financial Crimes Enforcement Network's (FinCEN) enforcement of the Beneficial Ownership...more
A Texas federal judge has ordered a stay of a nationwide injunction that placed the Corporate Transparency Act’s (“CTA”) filing requirements on hold. As a result, the CTA’s reporting requirements are back in effect. FinCEN...more
Companies are once again required to comply with the CTA and its reporting obligations. As discussed in our previous update, last month the Supreme Court of the United States (SCOTUS) stayed (i.e., suspended the effect of)...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 Jan. 23, the U.S. Supreme Court stayed the Dec. 5 nationwide injunction in Texas Top Cop Shop, Inc. v. Garland (E.D. Tex.) that had halted Corporate Transparency Act (“CTA”) enforcement nationwide. The stay of this...more
The Supreme Court has weighed in on the ongoing battle concerning the Corporate Transparency Act (the CTA). As we previously wrote, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a...more
On Jan. 24, 2025, FinCEN released a statement (screenshot below) acknowledging that the Corporate Transparency Act (CTA) remains enjoined given yet another injunction that has relieved business owners across the nation from...more
On January 23, 2024, the Supreme Court overturned a nationwide injunction enjoining enforcement of the Corporate Transparency Act (“CTA”). However, the implementing regulations of the CTA remain unenforceable due to a...more
A flurry of activity in the courts and guidance from FinCEN this week has the Corporate Transparency Act back in the news. However, the recent activity does not result in any immediate change for businesses. Filing beneficial...more
UPDATE: Please note there is a preliminary injunction against enforcement of the Corporate Transparency Act. The injunction, which applies nationwide, was granted by a Texas federal district court and such injunction has...more
“In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in...more
Not content to have an expedited hearing in March on the merits of the case at the Fifth Circuit Court of Appeals regarding the constitutionality of the Corporate Transparency Act (CTA), the Government filed an application...more
December 2024 gave businesses and practitioners whiplash trying to follow the bouncing ball about whether the Corporate Transparency Act was enforceable or unconstitutional. This article summarizes the events of the past...more
The Corporate Transparency Act (“CTA”) has been on a journey this past month with a whirlwind of court rulings: halted by a federal district court, reinstated by the Fifth Circuit’s motions panel, had its reporting deadlines...more
On December 26, 2024, in Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, 2024 WL 5224138 (5th Cir. Dec. 26, 2024), a merits panel of the United States Court of Appeals for the Fifth Circuit issued an order vacating the...more
Late on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed its own decision from earlier in the week, reinstating the nationwide preliminary injunction preventing the enforcement of the Corporate...more
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
In yet another twist in the Texas Top Cop Shop litigation challenging the constitutionality of the Corporate Transparency Act ("CTA"), on December 26, 2024, the United States Fifth Circuit Court of Appeals (the "Fifth...more
On December 26, 2024, the Fifth Circuit Court of Appeals vacated its earlier stay of the injunction suspending the reporting deadlines for the Corporate Transparency Act (the “CTA”)....more
On December 26, 2024, the Fifth Circuit Court of Appeals reinstated the nationwide preliminary injunction blocking enforcement of the Corporate Transparency Act (CTA). This decision was made to "preserve the constitutional...more
As of the posting of this article, reporting companies nationwide do not need to comply with the Corporate Transparency Act’s (CTA) revised beneficial owner information (BOI) reporting deadlines. The Fifth Circuit will...more