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Reporting Requirements FinCEN

Quarles & Brady LLP

Annual Update of Form ADV and Recent Regulatory Changes Affecting Advisers (UPDATED)

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As a reminder, each registered investment adviser must file an annual updating amendment to its Form ADV within 90 days of its fiscal year end. This means an adviser with a December 31 fiscal year end will be required to file...more

Bowditch & Dewey

Corporate Transparency Act – Potential Action by the Legislature

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On Tuesday, January 28, 2025, while an injunction blocking enforcement of the CTA remains in effect, a bipartisan bill was introduced on the floor of the House of Representatives, HR 9278, titled the “Protect Small Business...more

Miles Mediation & Arbitration

BOI Reports: What Business Owners and Attorneys Should Know

Starting last January, the U.S. Department of Treasury’s Financial Crimes Enforcement Network has opened a portal for businesses to file their beneficial ownership information reports (BOI). The BOI is the U.S. Treasury’s...more

Bass, Berry & Sims PLC

Supreme Court Enters the Corporate Transparency Act Fray, But Enforcement and Filings Remain on Hold

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On January 23, the U.S. Supreme Court lifted the nationwide injunction entered by the federal district court in the Eastern District of Texas in the case styled Texas Top Cop Shop v. McHenry, which had barred enforcement of...more

Orrick, Herrington & Sutcliffe LLP

Corporate Transparency Act Beneficial Reporting Still on Hold Nationwide – Stay Tuned

On January 23, 2025, the U.S. Supreme Court vacated one nationwide stay (Texas Top Cop Shop, Inc. v. McHenry – formerly, Texas Top Cop Shop v. Garland) which blocked the U.S. government from enforcing the Corporate...more

IR Global

Beneficial Ownership Reporting – To File or Not to File?

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Considering conflicting rulings, businesses remain understandably confused about whether to file their mandated Beneficial Ownership Reports with FinCen. As of this writing, the answer remains that businesses may file but are...more

Carlton Fields

Deadline Approaches for RIAs to Adopt AML Programs CIP Requirements Remain in Limbo

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On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) adopted a final rule that subjects investment advisers to the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). For...more

Seyfarth Shaw LLP

FinCEN Issues Further Guidance on Pausing CTA Compliance in Response to Supreme Court Ruling

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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

Saul Ewing LLP

Corporate Transparency Act Reporting Requirements Still on Hold

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The Corporate Transparency Act (CTA), enacted in 2021, mandates that companies disclose their true ownership to the Financial Crimes Enforcement Network (FinCEN) to combat illicit financial activities. However, its...more

Otten Johnson Robinson Neff + Ragonetti PC

CTA Enforcement Remains Paused Following Supreme Court Ruling Granting Stay of Injunction

On January 23, 2025, the Supreme Court of the United States granted the federal government’s motion to stay the nationwide injunction preventing enforcement of the Corporate Transparency Act (the “CTA”) entered by the United...more

Clark Hill PLC

CTA Litigation Update: Reporting Remains Voluntary

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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

Vinson & Elkins LLP

Supreme Court Grants Stay of Preliminary Injunction Against Corporate Transparency Act – Second Injunction Still In Effect

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On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry. As we discussed previously,...more

King & Spalding

CTA Compliance Stay Continues Despite Supreme Court Lifting Nationwide Injunction; FinCEN Recognizes Separate District Court Stay...

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On January 23, 2025, the U.S. Supreme Court granted the government’s motion to lift the nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in Texas Top Cop Shop v. McHenry (formerly, Texas Top...more

Akerman LLP

The U.S. Supreme Court Lifts Stay of Enforcement of the Corporate Transparency Act Yet Reporting Requirements Remain Voluntary

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On January 23, 2025, the Supreme Court of the United States (SCOTUS) lifted the nationwide injunction imposed by the District Court for the Eastern District of Texas in the case of Texas Top Cop Shop, Inc. v. Garland (Top Cop...more

Holland & Knight LLP

Supreme Court Stays CTA Injunction in Texas Top Cop Shop Case, but CTA Reporting Still on Hold

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In the Texas Top Cop Shop case, the U.S. District Court for the Eastern District of Texas on Dec. 3, 2024, issued an injunction that deferred all reporting requirements under the Corporate Transparency Act (CTA). (See Holland...more

Morris, Manning & Martin, LLP

Supreme Court Intervenes in CTA Legal Battle, But Implementation Still on Hold Due to Separate Injunction

The Supreme Court has weighed in on the ongoing battle concerning the Corporate Transparency Act (the CTA). As we previously wrote, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Says Reporting Obligations Remain On Hold

Last Friday, the United States Supreme Court lifted a nationwide injunction originally issued by the U.S. District Court for the Eastern District of Texas (and later upheld by the Fifth Circuit Court of Appeals) in Texas Top...more

Williams Mullen

Corporate Transparency Act Update: Still Enjoined, Filings Still Voluntary, No Penalties for Not Filing

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Corporate Transparency Act (CTA) news in January and December 2024 has been plentiful. Here is the running recap of significant December and January events...more

PilieroMazza PLLC

Corporate Transparency Act, Part 8: Supreme Court Weighs In; Voluntary Reporting Remains

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On January 23, 2025, the U.S. Supreme Court stayed the preliminary injunction issued by the U.S. District Court for the Eastern District of Texas in Texas Top Cop Shop, Inc., which halted reporting under the Corporate...more

Bricker Graydon LLP

The CTA is Back in Play, with a Slight Extension - Update

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On January 23, 2025, the U.S. Supreme Court lifted the nationwide injunction that had previously blocked the enforcement of the Corporate Transparency Act (CTA) (Texas Top Cop Shop, Inc. v. McHenry). The Supreme Court’s...more

Amundsen Davis LLC

Another Twist in the Corporate Transparency Act Saga: FinCEN Announces That Ownership Information Reporting Is Not Currently...

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced in an alert posted on its website on January 24, 2025, that reporting companies under the Corporate Transparency Act (CTA) are not...more

Warner Norcross + Judd

CTA Filing Obligations Remain Voluntary Amid Court Challenges

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After a few days on a legal roller coaster, enforcement and reporting obligations under the Corporate Transparency Act (CTA) remain on hold as lawsuits challenging the CTA’s constitutionality continue. On Jan. 23, 2025, the...more

Morrison & Foerster LLP

The Ping-Pong Continues – But CTA Is Still on Hold

On January 23, 2025, the U.S. Supreme Court granted the federal government’s motion to stay the nationwide injunction blocking the Corporate Transparency Act’s (CTA) enforcement, issued by the federal district court of the...more

Foodman CPAs & Advisors

NTA Addresses Overlap Reporting

On 1/8/25, the National Taxpayer Advocate (NTA) published its 2024 Annual Report to Congress and identified taxpayers’ problems and provided suggestions to further protect taxpayer rights and ease taxpayer burden. “By law,...more

Fenwick & West LLP

The Corporate Transparency Act: Reporting Obligations Remain Paused Despite Recent Court Developments

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Companies are still not required to comply with the Corporate Transparency Act (CTA)—despite a U.S. Supreme Court ruling on Thursday suggesting otherwise. On January 23, the High Court stayed a December 3 injunction in...more

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