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Please Click HerePosted on March 24, 2025 by Amy E. Ebeling, Jacob A. Schraeder and Morgan H. Sweeney
On March 21, 2025, FinCEN announced an end to Corporate Transparency Act (CTA) reporting requirements for U.S. citizens and domestic companies. In line with the U.S. Department of Treasuryโs announcement earlier this month, FinCEN has issued an interim final rule narrowing the scope of beneficial ownership information (BOI) reporting under the CTA. Under the interim [โฆ]
Posted on March 3, 2025 by Amy E. Ebeling, Jacob A. Schraeder and Morgan H. Sweeney
The U.S. Department of the Treasury suspended enforcement of the Corporate Transparency Act (CTA) for U.S. citizens and domestic reporting companies. On Sunday night, the Treasury announced that U.S. citizens and domestic reporting companies will no longer face penalties or fines for failure to report under the CTA. In its announcement, the Treasury stated it [โฆ]
Posted on February 18, 2025 by Amy E. Ebeling, Jacob A. Schraeder and Morgan H. Sweeney
The Corporate Transparency Act (CTA) and its reporting requirements are back in effect. This afternoon, a federal district court in Texas granted the U.S. governmentโs motion to stay (i.e., pause) the nationwide CTA injunction. Based on FinCENโs most recent alert, FinCEN intends to extend the reporting deadline for all reporting companies to 30 days from [โฆ]
Posted on February 17, 2025 by Amy E. Ebeling, Jacob A. Schraeder and Morgan H. Sweeney
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 legislative movements under the new administration, the status of the CTA could be facing imminent change. While there are several [โฆ]
Posted on January 24, 2025 by Amy E. Ebeling, Jacob A. Schraeder and Morgan H. Sweeney
In an alert posted this morning, FinCEN has announced that reporting companies are not currently required to file beneficial ownership reports even with the U.S. Supreme Courtโs order yesterday. Instead of issuing a new deadline for filing reports, FinCEN stated that despite the Supreme Court granting a stay (i.e., pause) of the nationwide block on [โฆ]
Posted on January 23, 2025 by Amy E. Ebeling, Jacob A. Schraeder and Morgan H. Sweeney
The Corporate Transparency Act (โCTAโ) and its beneficial ownership reporting requirements are back in effect. Earlier today, the U.S. Supreme Court granted the federal governmentโs request to stay (i.e., pause) the nationwide block on enforcing the CTA. The merits of the CTA are still under review by the 5th Circuit Court of Appeals, with oral [โฆ]
Posted on January 3, 2025 by Amy E. Ebeling, Jacob A. Schraeder and Morgan H. Sweeney
The Corporate Transparency Act (โCTAโ) has been on a journey this past month with a whirlwind of court rulings: halted by a federal district court, reinstated by the Fifth Circuitโs motions panel, had its reporting deadlines extended by FinCEN, and then halted again by the Fifth Circuitโs merits panel. Amidst all this back-and-forth, predicting what [โฆ]
Posted on December 27, 2024 by Amy E. Ebeling, Jacob A. Schraeder and Morgan H. Sweeney
The U.S. Court of Appeals for the Fifth Circuit has once again vacated enforcement of the Corporate Transparency Act (CTA) and its reporting requirements. This latest decision temporarily halts the mandate for entities to disclose beneficial ownership information to the Financial Crimes Enforcement Network (FinCEN), reinstating a pause on compliance obligations. The appellate courtโs panel [โฆ]
Posted on December 24, 2024 by Amy E. Ebeling, Jacob A. Schraeder and Morgan H. Sweeney
FinCEN has extended the reporting deadline for companies created or registered before January 1, 2024, to January 13, 2025. In an alert posted Tuesday night, FinCEN recognized that โreporting companies may need additional time to comply given the period when the preliminary injunction had been in effect.โ Previously, the reporting deadline for these companies was [โฆ]
Posted on December 23, 2024 by Amy E. Ebeling, Jacob A. Schraeder and Morgan H. Sweeney
The Corporate Transparency Act (โCTAโ) and its reporting requirements are back in effect. The Fifth Circuit Court of Appeals has granted the U.S. Governmentโs motion for an emergency stay of the nationwide CTA injunction. This means the federal injunction that sought to overrule or pause the CTA is temporarily halted. As a result, reporting companies [โฆ]