News & Analysis as of

Department of Justice (DOJ) FinCEN Supreme Court of the United States

Greenbaum, Rowe, Smith & Davis LLP

Another Urgent Update: Corporate Transparency Act is Again Enforceable with New Deadline for Reporting

We previously reported that on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated the Fifth Circuit motion panel’s stay of the Corporate Transparency Act (CTA) of the temporary injunction granted by...more

McCarter & English, LLP

The Evolution of the CTA: Beneficial Ownership Information Reports Are Due by March 21, 2025

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

Miller Canfield

Recent Developments: Nationwide CTA Injunction Lifted, New March 21, 2025, Reporting Deadline Set, and Reporting Rule May Be...

Miller Canfield on

On January 23, 2025, the United States Supreme Court (SCOTUS) reversed the U.S. district court’s preliminary injunction staying the Corporate Transparency Act (CTA) and the implementing Reporting Rule in Texas Top Cop Shop v...more

Proskauer Rose LLP

Ping Pong Rules: Corporate Transparency Act Back in Effect (Again)

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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

Wiley Rein LLP

Corporate Transparency Act Reinstated; New March Deadline for BOI Reports

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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

Dorsey & Whitney LLP

U.S. Government Appeals CTA Injunction - But Changes to Reporting Requirements May Be On The Horizon

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As we previously reported, on January 23, 2025, the Supreme Court of the United States ruled in favor of the U.S. government in relation to the Corporate Transparency Act (“CTA”) – granting an emergency application to...more

Kerr Russell

Corporate Transparency Act Enforcement Expected to Resume Following Legal Developments

Kerr Russell on

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

Orrick, Herrington & Sutcliffe LLP

Corporate Transparency Act Beneficial Reporting Still on Hold Nationwide – Stay Tuned

On January 23, 2025, the U.S. Supreme Court vacated one nationwide stay (Texas Top Cop Shop, Inc. v. McHenry – formerly, Texas Top Cop Shop v. Garland) which blocked the U.S. government from enforcing the Corporate...more

Vinson & Elkins LLP

Supreme Court Grants Stay of Preliminary Injunction Against Corporate Transparency Act – Second Injunction Still In Effect

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On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry. As we discussed previously,...more

Dickinson Wright

Supreme Court Stays Fifth Circuit CTA Injunction, But Clarity Remains Elusive

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On Jan. 23, 2025, the United States Supreme Court reinstated a stay on the Fifth Circuit Court of Appeals’ Dec. 26, 2024, decision, which had upheld a lower court’s nationwide injunction blocking enforcement of the Corporate...more

Morgan Lewis

CTA Still On Hold: US Supreme Court Lifts One Injunction, But Another Remains

Morgan Lewis on

The US Supreme Court has granted FinCEN’s request for a stay of the recent nationwide injunction of enforcement of the Corporate Transparency Act (CTA). A separate nationwide injunction, however, remains in place, meaning...more

Amundsen Davis LLC

Another Twist in the Corporate Transparency Act Saga: FinCEN Announces That Ownership Information Reporting Is Not Currently...

Amundsen Davis LLC on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced in an alert posted on its website on January 24, 2025, that reporting companies under the Corporate Transparency Act (CTA) are not...more

Robinson & Cole LLP

Legal Update: No Enforcement of Corporate Transparency Act Despite SCOTUS Ruling

Robinson & Cole LLP on

On January 23, 2025, in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., the Supreme Court of the United States (SCOTUS) granted the government the ability to lift the injunction which halted enforcement of...more

Kerr Russell

CTA Enforcement Remains Suspended Amid Ongoing Litigation

Kerr Russell on

On January 23, 2025, the U.S. Supreme Court granted the U.S. Department of Justice’s request to stay the nationwide injunction that had previously banned enforcement of the Corporate Transparency Act (CTA) and its key...more

McCarter & English, LLP

The Evolution of the CTA: BOIR Filing Still Voluntary (For Now)

Jaunary 23, the US Supreme Court (SCOTUS) issued a highly anticipated decision with respect to the reporting requirements and enforcement of the Corporate Transparency Act (31 U.S.C. § 5336, the CTA). As summarized below, a...more

Husch Blackwell LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act -

Husch Blackwell LLP on

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, though the situation may...more

Wiley Rein LLP

CTA Update: Supreme Court Temporarily Lifts Injunction, but Requirements Remain Blocked

Wiley Rein LLP on

On January 23, 2025, the U.S. Supreme Court issued a ruling that appears to settle – for now – a nearly two-month-long legal battle over the Corporate Transparency Act (CTA), which began with a nationwide preliminary...more

McGuireWoods LLP

U. S. Supreme Court Vacates National Injunction Staying the CTA in One Case, But a Separate Nationwide Stay Against Enforcement...

McGuireWoods LLP on

Here we go again – another CTA update hot off the press. In our last update, we reported that the U.S. Department of Justice (DOJ) filed with the U.S. Supreme Court an emergency application to stay the injunction...more

Arnall Golden Gregory LLP

U.S. Supreme Court Lifts Fifth Circuit Court of Appeals Injunction Reinstating Filing Requirements Under Corporate Transparency...

This is the sixth installment in our ongoing series of client alerts on the Corporate Transparency Act (the “CTA”)....more

Amundsen Davis LLC

U.S. Supreme Court Provisionally Reinstates the Corporate Transparency Act

Amundsen Davis LLC on

The U.S. Supreme Court issued an order on January 23, 2025, which provisionally reinstates the Corporate Transparency Act (CTA) while a legal challenge to it continues. This brief order, which stayed an injunction against the...more

McGuireWoods LLP

DOJ Seeks Supreme Court Review of CTA Injunction

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Another flurry of court activity has further muddied the Corporate Transparency Act (CTA) waters, leaving additional uncertainty about its enforceability. You may recall that on December 26, 2024, the Fifth Circuit...more

Holland & Knight LLP

CTA: Government's Emergency Application to Supreme Court to Impose Stay – What's Next?

Holland & Knight LLP on

As reported by Holland & Knight on Dec. 27, 2024, companies and individuals impacted by the Corporate Transparency Act (the CTA) reasonably could have believed there was a respite from the "off again, on again, off again"...more

Lerman Senter PLLC

Fifth Circuit Reinstates Stay on Ownership Reporting - Deadline Lifted

Lerman Senter PLLC on

On December 26, 2024, the Fifth Circuit reinstated a stay of the Corporate Transparency Act’s requirement that businesses must file Beneficial Ownership Information reports. Accordingly, there is at present no obligation to...more

Rivkin Radler LLP

The Status of the Corporate Transparency Act – It’s Not Clear

Rivkin Radler LLP on

Few would argue that the federal government does not have a legitimate interest in preventing, detecting, and punishing tax fraud, money laundering, and other financial crimes. Likewise, I imagine few would disagree with the...more

Snell & Wilmer

Is the Corporate Transparency Act Going To Be Brought Back to Life?

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On December 5, 2024, the Department of Justice (DOJ), filed a Notice of Appeal in response to a U.S. District Court’s recently issued, nationwide preliminary injunction stopping the reporting obligations under the Corporate...more

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