News & Analysis as of

Reporting Requirements Fourth Amendment

Lathrop GPM

Dept. of Education Certification Requirement Tied to “Antidiscrimination Obligations” for Continued K-12 Federal Funding

Lathrop GPM on

On April 3, 2025, the U.S. Department of Education (ED) issued a press release announcing the ED sent certification letters to state commissions that oversee K-12 State Education Agencies (SEAs), charging SEAs with the...more

Allen Matkins

Will Ling Chi Kill The Corporate Transparency Act?

Allen Matkins on

Ling Chi was a slow and torturous method of execution practiced in Imperial China.  Better known in English as "death by a thousand cuts", ling chi took a terribly long time to kill the condemned prisoner....more

BCLP

Treasury Suspends CTA Enforcement Against U.S. Citizens and Companies; Federal District Court Declares CTA Unconstitutional

BCLP on

The Corporate Transparency Act (the “CTA”) remains in full force and effect, although FinCEN recently announced that it will not take any enforcement actions against reporting companies who fail either to file or to update...more

Miller Canfield

Michigan Federal Court Holds CTA Reporting Rule Unconstitutional, Enjoins Enforcement Against Named Plaintiffs

Miller Canfield on

On March 3, 2025, a Michigan federal district court in Small Business Association of Michigan v Yellen, Case No. 1:24-cv-413 (W.D Mich 2025) (SBAM), held that the CTA’s reporting rule is unconstitutional under the Fourth...more

Foster Garvey PC

FinCEN Delivers Some Good News About Its Enforcement of the Corporate Transparency Act

Foster Garvey PC on

On Thursday, February 27, 2025, FinCEN announced that it will not issue any penalties or pursue enforcement action against reporting companies for the mere failure to meet the current filing deadlines. That news for many is...more

Wiley Rein LLP

Treasury Says It Won’t Enforce Corporate Transparency Act Against U.S. Companies or Citizens

Wiley Rein LLP on

Treasury / FinCEN - Interim Final Rule and Proposed Rulemaking - On March 2, 2025, the U.S. Department of the Treasury issued a press release stating that it will not enforce any penalties or fines against U.S. citizens or...more

Rothwell, Figg, Ernst & Manbeck, P.C.

Update: The Corporate Transparency Act Put On Hold

As an update to our post on the Corporate Transparency Act, on December 3, 2024, a federal district court issued a nationwide preliminary injunction pertaining to the Corporate Transparency Act in Texas Top Cop Shop, Inc. v....more

McCarter & English, LLP

Corporate Transparency Act: Preliminary Injunction & FinCen’s Response

McCarter & English, LLP on

The Corporate Transparency Act (31 U.S.C. § 5336, the CTA), which went into effect on January 1, 2024, requires a broad range of corporations, limited liability companies, and other entities (“reporting companies”) to file...more

Best Best & Krieger LLP

Texas Federal Court Blocks Enforcement of Corporate Transparency Act

Best Best & Krieger LLP on

On Tuesday December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction which precludes enforcement of the Corporate Transparency Act (CTA) (See, Texas Top Cop Shop,...more

McNees Wallace & Nurick LLC

Corporate Transparency Act Dealt Blow by Eastern District of Texas: How Reporting Companies Can Proceed

On Tuesday, December 3, 2024, the Federal District Court for the Eastern District of Texas (the “Court”) issued an opinion in Texas Top Cop Shop, Inc. et al. v. Merrick Garland, Attorney General of the United States, et al....more

The Wagner Law Group

Texas District Court Issues Nationwide Preliminary Injunction Against Enforcement of Corporate Transparency Act (CTA)

The Wagner Law Group on

When page 1 of a District Court decision on a challenge on constitutional grounds to an action by a governmental entity cites Marbury v. Madison, that is not a good sign for the government agency. When page 2 of a District...more

White and Williams LLP

Federal Court Suspends Enforcement of the Corporate Transparency Act’s Reporting Requirements

White and Williams LLP on

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction prohibiting the federal government from enforcing the Corporate Transparency Act (the “CTA”) nationwide. Texas Top...more

Pierce Atwood LLP

Federal Government Appeals Suspension of Corporate Transparency Act Deadline

Pierce Atwood LLP on

On December 3, 2024, the Eastern District of Texas issued a nationwide preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA), less than a month before the deadline. The ruling temporarily...more

Greenberg Glusker LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act

Greenberg Glusker LLP on

UPDATE as of 12/7/2024: FinCen has updated their website addressing the recent federal court order, publicly stating that reporting companies are not currently required to file beneficial ownership information with FinCEN and...more

Flaster Greenberg PC

Preliminary Injunction Blocking Enforcement of the Corporate Transparency Act

Flaster Greenberg PC on

We previously discussed a ruling by a federal District Court in Alabama finding that the Corporate Transparency Act (“CTA”) was unconstitutional, with the holding limited to the plaintiffs in the case. For general background...more

King & Spalding

Federal District Court in Texas Grants “Nationwide” Preliminary Injunction Against CTA Enforcement

King & Spalding on

On December 3, 2024, the United States District Court for the Eastern District of Texas entered a nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (“CTA”) and its implementing...more

Farella Braun + Martel LLP

Nationwide Injunction Halts Corporate Transparency Act Enforcement

A recent federal court decision eliminates the present need for any person or company to comply with the Corporate Transparency Act (CTA) and its implementing regulations. This decision may be reversed upon appeal, but as of...more

Akin Gump Strauss Hauer & Feld LLP

Federal Court Issues Preliminary Injunction of CTA

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction regarding enforcement of the Corporate Transparency Act (CTA) and related beneficial ownership reporting rule. The...more

Adams & Reese

“Christmas Curveball” – CTA Temporarily Blocked Nationwide by Texas Court Injunction

Adams & Reese on

A Texas federal court judge has thrown a Christmas curveball at FinCEN with less than one month remaining before the CTA deadline of Jan. 1, 2025. On that date more than 30 million companies would be required to report their...more

Holland & Hart LLP

What Does the Nationwide Preliminary Injunction of the Corporate Transparency Act Mean for Businesses?

Holland & Hart LLP on

On December 3, 2024, the U.S. District Court for the Eastern District of Texas granted a nationwide preliminary injunction barring enforcement of the Corporate Transparency Act (CTA)1 and its key implementing regulations...more

Snell & Wilmer

The Corporate Transparency Act – Is it on Life Support?

Snell & Wilmer on

In Texas Top Cop Shop, Inc. et al. v. Merrick Garland, a U.S. District Court in Texas has issued a potentially major setback to the continued application of the Corporate Transparency Act (CTA), which became effective on...more

Bracewell LLP

Texas Court Issues Nationwide Preliminary Injunction of the Corporate Transparency Act

Bracewell LLP on

On December 3, 2024, the US District Court for the Eastern District of Texas issued a nationwide preliminary injunction, halting enforcement of the Corporate Transparency Act (CTA) and its implementing regulations....more

Seward & Kissel LLP

Corporate Transparency Act Blocked by Recent Injunction

Seward & Kissel LLP on

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction prohibiting the federal government from enforcing the Corporate Transparency Act (the “CTA”) nationwide (Texas Top...more

Ward and Smith, P.A.

Legal Pause: Preliminary Injunction on Corporate Transparency Act Enforcement

Ward and Smith, P.A. on

On December 3, 2024, in the matter of Texas Top Cop Shop, Inc., et al. v. Garland, et al., the U. S. District Court for the Eastern District of Texas (Sherman District) issued a preliminary injunction against the Corporate...more

Warner Norcross + Judd

Preliminary Injunction Temporarily Prevents CTA Enforcement Nationwide — But Likely is Not the Last Word Before December 31

Warner Norcross + Judd on

On December 3, 2024, in Texas Top Cop Shop, Inc. v. Garland, the U.S. District Court for the Eastern District of Texas entered a preliminary injunction that prevents enforcement of the Corporate Transparency Act (CTA) and its...more

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