News & Analysis as of

Reporting Requirements Stays

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

Holtzman Vogel Baran Torchinsky & Josefiak

In-Compliance: Holtzman Vogel's January 2025 Round-Up

Supreme Court Lifts Fifth Circuit’s Corporate Transparency Act Injunction; Second District Court Enjoins Beneficial Ownership Reporting Rule and Requirements Remain Fluid - On January 23, 2025, the U.S. Supreme Court...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

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

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

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

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

Bricker Graydon LLP

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

Bricker Graydon LLP on

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

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

Fenwick & West LLP

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

Fenwick & West LLP on

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

Cozen O'Connor

A CTA Injunction Remains Despite Supreme Court Stay

Cozen O'Connor on

On January 23, 2025, the U.S. Supreme Court stayed the injunction issued by the Fifth Circuit Court of Appeals in the case of Texas Top Cop Shop, Inc. v. Garland, et al. Case No. 4:24-cv-478 (E.D. Tex.) (Texas Top Cop Case)....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

McGlinchey Stafford

Game On – Again, Not Exactly: Supreme Court Stays CTA Universal Injunction

McGlinchey Stafford on

The rollercoaster has more hills and turns. On January 23, 2025, the U.S. Supreme Court agreed that the Government is entitled to a stay of the universal injunction of the Corporate Transparency Act (CTA). In light of this...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

Cole Schotz on

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

Hinshaw & Culbertson LLP

UPDATE: SCOTUS Stayed a CTA Injunction Under the "Texas Top Cop Shop" Action, BUT the CTA is Still NOT Back in Effect

In the latest twist on the back-and-forth CTA battle, on January 23, 2025, the Supreme Court of the United States (SCOTUS) once again stayed (i.e., suspended the effect of) the nationwide preliminary injunction against...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

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

Pullman & Comley, LLC

Despite Supreme Court Granting Stay, CTA Enforcement Remains Paused

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On January 23, 2025, it appeared that the Supreme Court had given the green light to FinCEN to resume enforcement of the Corporate Transparency Act (CTA) and its beneficial ownership information reporting requirements after...more

Benesch

On Again, Off Again – CTA Preliminary Injunction Stayed by Supreme Court

Benesch on

On January 23, 2025, the Supreme Court stayed an injunction blocking enforcement of the Corporate Transparency Act’s (“CTA”) beneficial ownership information (“BOI”) requirement. McHenry v. Texas Top Cop Shop, Inc., 604...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

BCLP

SCOTUS Stays Nationwide Injunction of the CTA; But Different District Court Nationwide Stay of Reporting Deadline Still in Effect...

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As previously reported, on December 31, 2024, the government filed an application in the Supreme Court of the United States to stay or narrow the Fifth Circuit’s preliminary nationwide injunction halting the Corporate...more

White and Williams LLP

Corporate Transparency Act – Supreme Court Weighs In

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December was a busy month of back-and-forth, on again and off again, for the Corporate Transparency Act’s (“CTA”) beneficial ownership information reporting requirements. On Thursday, January 23, 2025, the Supreme Court...more

Adams and Reese LLP

SCOTUS Allows Enforcement of Corporate Transparency Act; FinCEN Says Reporting is Voluntary for Now

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As the calendar turns to 2025, there is a new development in the off-again, on-again Corporate Transparency Act (“CTA”). This time, the highest court has weighed in....more

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