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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
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
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
On Feb. 17, 2025, the U.S. District Court for the Eastern District of Texas (in Smith, et al. v. U.S. Department of the Treasury, et al.) granted the federal government’s motion to stay a nationwide preliminary injunction...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
After months of litigation, the Corporate Transparency Act (“CTA”) is once again effective, and most companies subject to the CTA are required to file Beneficial Ownership Information (“BOI”) reports with the U.S. Treasury’s...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
Here are the latest developments in the ongoing Corporate Transparency Act (CTA) saga...more
The Corporate Transparency Act (“CTA”) continues to take reporting companies on a roller coaster ride. Now, there are not just one, but two Eastern District of Texas federal cases challenging the requirement for certain...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
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
On January 23, the U.S. Supreme Court lifted a nationwide preliminary injunction on the enforcement of the Corporate Transparency Act (the CTA), a law requiring millions of business entities to report information about their...more
Enforcement of the Corporate Transparency Act (the “CTA”) remains on hold while litigation proceeds, and reporting companies are therefore not required to file reports at this time. However, reporting companies may continue...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
(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