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FinCEN’s Weekend Present: No More CTA for U.S. Companies

As discussed in our March 4 Client Alert, following its February 27 and March 2 announcements suspending enforcement of the Corporate Transparency Act (CTA) and promising additional CTA compliance guidance, on the evening of...more

FinCEN Announces No Fines or Penalties Under the CTA Pending New Rulemaking, New Narrowed Enforcement Scope

As discussed in our prior client alert, following the February 18 decision by the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Dep’t of Treasury to stay a nationwide injunction it previously entered...more

Back to the Future: Compliance with the CTA is Compulsory Once Again

Regular readers of our prior client alerts know that compliance with the Corporate Transparency Act’s (CTA) beneficial ownership requirements has been on-again-off-again multiple times over the last few months following...more

Déjà Vu All Over Again: Fifth Circuit Vacates Its Own Stay; CTA Compliance Is Now Optional Once Again (for Now)

In a surprise ruling, December 26, the Fifth Circuit Court of Appeals vacated its own stay of the Eastern District of Texas’ Dec. 3 nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act...more

Lump of Coal in the CTA Stocking: Texas Federal Court of Appeals Stays Injunction Against Corporate Transparency Act

The U.S. Court of Appeals for the Fifth Circuit has granted the government’s motion to stay the Eastern District of Texas’ December 3 nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act...more

Texas Federal District Court Rules Corporate Transparency Act Likely Unconstitutional, Issues Nationwide Preliminary Injunction

On December 3, 2024, a federal district court in Texas issued a nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA).1 The court indicated that the CTA is “likely unconstitutional,”...more

Don’t pop the champagne; the CTA isn’t dead ... yet.

On Friday, March 1, 2024, U.S. District Court Judge Liles Burke ruled that the Corporate Transparency Act (CTA) is unconstitutional because Congress exceeded its powers to regulate interstate commerce, oversee foreign affairs...more

About Time: FinCEN Extends Deadline for New Companies Reporting Beneficial Ownership Information

On November 29, 2023, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (RIN 1506-AB62)1, extending the deadline for companies created or registered in 2024 to file beneficial owner...more

Bipartisan Bill Seeks to Delay FinCEN’s Beneficial Ownership Reporting Requirements

On August 1, a bipartisan bill was introduced to modify the Corporate Transparency Act (CTA). The Protect Small Businesses and Prevent Illicit Financial Activity Act (H.R. 5119) was introduced in the U.S. House of...more

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