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On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more
On December 23, 2024, the Court of Appeals for the Fifth Circuit stayed the nationwide injunction enjoining the U.S. government from enforcing the Corporate Transparency Act (the “CTA”) and the corresponding reporting...more
The U.S. Court of Appeals for the Fifth Circuit reinstated and then subsequently suspended the reporting requirements under the Corporate Transparency Act (the “CTA”) over the course of the last week by staying the original...more
On December 26, 2024, the Court of Appeals for the Fifth Circuit VACATED a ruling early this week to stay the nationwide injunction enjoining the U.S. government from enforcing the Corporate Transparency Act (the “CTA”) and...more
Late on December 26, 2024, a panel of the Fifth Circuit ordered the injunction back into effect. Timing is uncertain for any oral arguments or other court rulings....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
As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the Corporate Transparency Act (“CTA”). Texas Top Cop...more
On Thursday, December 26, 2024, the United States Court of Appeals for the Fifth Circuit reinstated the nationwide injunction staying the CTA filing deadline....more
As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction blocking the U.S. Department of Treasury from enforcing the Corporate...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 previously reported, on December 23, 2024, a motions panel of the U.S. Court of Appeals for the Fifth Circuit grants the government’s emergency motion in the Texas Top Cop Shop matter to stay the preliminary nationwide...more
Corporate Transparency Act (CTA) news in December 2024 has been plentiful. Here is the running recap of significant December events...more
After our December 23 News Alert, FinCEN announced an extension for all filings due by 12/31/2024 for entities formed prior to January 1, 2024. Such subject entities now must file no later than January 13, 2025....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
We have previously shared updates regarding the Corporate Transparency Act (CTA), which generally requires so-called “Reporting Companies” to disclose the individuals who meaningfully control and own such companies to the...more
On December 23, 2024, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit reversed a Texas district court order that had granted a preliminary injunction of the Beneficial Ownership Information (BOI)...more
On December 23, 2024, the United States Court of Appeals for the Fifth Circuit granted the government’s emergency motion and stayed the temporary nationwide injunction that prohibited enforcement of the Corporate Transparency...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
In an order issued December 23, 2024, the United States Court of Appeals for the Fifth Circuit set aside a nationwide injunction that had suspended the requirements of the Corporate Transparency Act (“CTA”) and regulations...more