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Only Foreign Entities Need to Report Under the CTA

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department, issued a new interim final rule on reporting under the Corporate Transparency Act (CTA). The new rule drastically...more

CTA Reporting and Enforcement Suspended Indefinitely

In a whirlwind series of announcements, the Treasury Department and FinCEN have suspended all Corporate Transparency Act (CTA) reporting and enforcement for domestic entities indefinitely. On Feb. 27, FinCEN announced that...more

CTA Back in Effect – Reports Now Due March 21

On Feb. 18, the U.S. District Court in Smith, et al v. U.S. Dept. of Treasury stayed the last remaining nationwide injunction on enforcement of the Corporate Transparency Act. After this court action, FinCEN announced that...more

CTA Litigation Update: Reporting Remains Voluntary

On Jan. 23, the U.S. Supreme Court stayed the Dec. 5 nationwide injunction in Texas Top Cop Shop, Inc. v. Garland (E.D. Tex.) that had halted Corporate Transparency Act (“CTA”) enforcement nationwide. The stay of this...more

Nationwide CTA Injunction Back in Effect Pending Fifth Circuit Appeal

On Dec. 26, the Fifth Circuit Court of Appeals effectively reinstated the nationwide preliminary injunction against the Corporate Transparency Act. After the Fifth Circuit’s emergency “motions panel” lifted the injunction on...more

CTA Injunction Lifted and Additional Reporting Time Provided

UPDATE: The nationwide preliminary injunction against the Corporate Transparency Act is back in effect as of Dec. 26, 2024. The Fifth Circuit Court of Appeals vacated its prior order lifting the injunction. The preliminary...more

Nationwide Injunction Halts Corporate Transparency Act Enforcement

A U.S. District Judge issued a nationwide preliminary injunction prohibiting FinCEN from enforcing the Corporate Transparency Act (CTA) and the final rule implementing it (Reporting Rule) on Dec. 3 in the case Texas Top Cop...more

Exercise Caution in Corporate Transparency Act Compliance Matters

Threat actors never miss an opportunity to use recent events to infect computer systems or quickly and easily gather personal information. The Corporate Transparency Act (“CTA”) is just such an opportunity and businesses and...more

Corporate Transparency Act: Understanding the “Large Operating Company” Exemption

On Jan. 1, the new Corporate Transparency Act (“CTA”) came into effect and imposes reporting obligations on domestic and foreign entities that are within the scope of the definition of “reporting company” under the statute....more

Preparing for the Corporate Transparency Act (Updated)

Originally published October 2023, updated January 2024. The Corporate Transparency Act (CTA) was enacted on Jan. 1, 2021, and requires new beneficial ownership reporting for U.S. and foreign companies. Reporting...more

Preparing for the Corporate Transparency Act

The Corporate Transparency Act (CTA) was enacted on Jan. 1, 2021, and will require new beneficial ownership reporting for U.S. and foreign companies. Reporting requirements under 31 U.S.C. § 5336 are anticipated to begin Jan....more

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