News & Analysis as of

Reporting Requirements FinCEN Constitutional Challenges

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

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

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

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

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

PilieroMazza PLLC on

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

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

Cadwalader, Wickersham & Taft LLP

Corporate Transparency Act Remains on Hold Despite SCOTUS Stay of Injunction

On January 23, 2024, the Supreme Court overturned a nationwide injunction enjoining enforcement of the Corporate Transparency Act (“CTA”).  However, the implementing regulations of the CTA remain unenforceable due to a...more

Verrill

Status of CTA Reporting Rule as of January 24, 2025

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FinCEN announced on January 24: In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to...more

Moore & Van Allen PLLC

Corporate Transparency Act Reporting Obligations Remain Paused Despite Supreme Court Order

Moore & Van Allen PLLC on

On January 23, 2025, the United States Supreme Court ruled on McHenry v. Texas Top Cop Shop, Inc., granting the Government’s application to stay the injunction of the Corporate Transparency Act (“CTA”) initially ordered by...more

McCarter & English, LLP

The Evolution of the CTA: BOIR Filing Still Voluntary (For Now)

Jaunary 23, the US Supreme Court (SCOTUS) issued a highly anticipated decision with respect to the reporting requirements and enforcement of the Corporate Transparency Act (31 U.S.C. § 5336, the CTA). As summarized below, a...more

Husch Blackwell LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act -

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As of the posting of this article, reporting companies nationwide do not need to comply with the Corporate Transparency Act’s (CTA) revised beneficial owner information (BOI) reporting deadlines, though the situation may...more

Cole Schotz

CTA Update: Companies Not Required To File Under The CTA, Despite Supreme Court Stay

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Despite a Supreme Court order issued on January 23, 2025, as of January 24, 2025, FinCEN has stated they are not requiring companies to file under the CTA. On January 23, 2025, the U.S. Supreme Court, in an unsigned order,...more

Wiley Rein LLP

CTA Update: Supreme Court Temporarily Lifts Injunction, but Requirements Remain Blocked

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On January 23, 2025, the U.S. Supreme Court issued a ruling that appears to settle – for now – a nearly two-month-long legal battle over the Corporate Transparency Act (CTA), which began with a nationwide preliminary...more

Bond Schoeneck & King PLLC

Corporate Transparency Act BOI Reports are Still Voluntary

Despite the Supreme Court’s decision to stay the injunction issued against the enforcement of the Corporate Transparency Act (CTA), reporting companies are still not required to file their BOI Reports. In Smith v. United...more

Rivkin Radler LLP

SCOTUS Hands Down CTA Decision — FinCEN Says Reporting Requirements Remain on Pause

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The Financial Crimes Enforcement Network (“FinCEN”) announced on Friday, January 24, 2025, that reporting companies are not currently required to file beneficial ownership information (“BOI”) under the Corporate Transparency...more

Maynard Nexsen

FinCEN Confirms Compliance with Corporate Transparency Act Remains Voluntary

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In response to the Supreme Court’s opinion released yesterday granting the government’s motion to stay the nationwide injunction issued in Texas Top Cop Shop, Inc. v. McHenry, the Financial Crimes Enforcement Network...more

Kilpatrick

Corporate Transparency Act Still Enjoined Despite Recent Supreme Court Ruling

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We previously reported that on December 26, 2024, a panel of the United States Court of Appeals for the Fifth Circuit restored the nationwide preliminary injunction against enforcement of the federal Corporate Transparency...more

Dorsey & Whitney LLP

SCOTUS Overturns One CTA Nationwide Injunction - but Reporting Requirements Still Paused…

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On January 23, 2025, the Supreme Court of the United States ruled in favor of the U.S. government in relation to the Corporate Transparency Act (“CTA”) – granting an emergency application to overturn the nationwide...more

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