On March 26, 2025, the Financial Crimes Enforcement Network’s (“FinCEN”) interim final rule (the “Interim Rule”) exempting domestic entities and U.S. persons from reporting beneficial ownership information (“BOI”) under the...more
Two recent announcements from the Financial Crimes Enforcement Network (FinCEN) and the U.S Department of the Treasury provide some, at least momentary, relief with respect to the Corporate Transparency Act’s (CTA) Beneficial...more
January 24, 2025 Update: On January 24, FinCEN published updated reporting guidance in which it announced that reporting companies are not currently required to file beneficial ownership information with FinCEN despite the...more
On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit issued an order temporarily staying the nationwide preliminary injunction previously granted in Texas Top Cop Shop, Inc., et al. v. Garland, et al. While...more
12/27/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Filing Deadlines ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
This article provides Corporate Transparency Act (CTA) guidance to tax-exempt organizations with subsidiaries. For a general overview of CTA compliance for nonprofit and tax-exempt organizations, please see Part 1: When to...more
The Corporate Transparency Act (CTA) took effect on January 1, 2024 and some U.S. nonprofits and tax-exempt organizations are still debating how the CTA applies to them. This article provides newly-formed and existing...more
Corporate structures in commercial real estate transactions can often be very complex and involve layers of entities. Special purpose entities that are bankruptcy remote (“SPEs”) are frequently used in commercial real estate...more
5/9/2024
/ Bankruptcy Court ,
Banks ,
Beneficial Owner ,
Borrowers ,
Commercial Real Estate Market ,
Corporate Transparency Act ,
FinCEN ,
Lenders ,
Loans ,
Mortgages ,
Real Estate Transactions ,
Special Purpose Entities
The Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) that became law on March 27, 2020 provides several enhanced tax incentives for charitable giving in 2020 (and beyond) by individuals and corporations. ...more