CORPORATE TRANSPARENCY ACT UPDATE: FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Persons and U.S. Entities

On March 21, 2025, FinCEN announced the release of a new interim final rule that removes the beneficial ownership reporting requirements for companies formed in the U.S. and U.S. persons under the CTA.  On March 26, 2025, the new interim final rule was published in the Federal Register and FinCEN published a Q&A offering additional…

CORPORATE TRANSPARENCY ACT UPDATE: U.S. Department of Treasury Suspends Enforcement of the CTA Against U.S. Citizens and Domestic Reporting Companies

On March 2, 2025, the U.S. Department of Treasury announced that it will not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, and that it will not enforce any penalties or fines against U.S. Citizens or domestic reporting companies or their beneficial owners after the…

CORPORATE TRANSPARENCY ACT (“CTA”) UPDATE: The CTA Reporting Requirements Are Back Once Again

The last remaining preliminary injunction blocking enforcement of the CTA on a nationwide basis has now been lifted and the CTA has been reinstated nationwide.  On February 17, 2025, in Smith v. U.S. Department of Treasury, a federal judge in the United States District Court for the Eastern District of Texas issued an order staying…

NEW CORPORATE TRANSPARENCY ACT UPDATE: Supreme Court of the United States Stays the Preliminary Injunction Blocking Enforcement of the CTA

On January 23, 2025, the Supreme Court of the United States issued a stay on the preliminary injunction that temporarily blocked enforcement of the Corporate Transparency Act (“CTA”) and its reporting rule on a nationwide basis.  This stay will remain in effect until the U.S. Court of Appeals for the Fifth Circuit renders a decision…

NEW CORPORATE TRANSPARENCY ACT UPDATE: Fifth Circuit Court Vacates its Stay to the Preliminary Injunction Blocking Enforcement of the CTA

On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated its prior December 23, 2024 decision to stay the December 3, 2024 preliminary injunction that temporarily blocked enforcement of the Corporate Transparency Act (“CTA”) and its reporting rule on a nationwide basis.  As of the date of this notice and on…

CORPORATE TRANSPARENCY ACT UPDATE: Fifth Circuit Court Stays Preliminary Injunction Blocking Enforcement of the CTA; FinCEN Issues Updated Guidance

On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit stayed the December 3, 2024 preliminary injunction that temporarily blocked enforcement of the Corporate Transparency Act (“CTA”) and its reporting rule on a nationwide basis.  As of the date of this notice, the CTA has been reinstated nationwide.   In light of…