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3.27.25
The Corporate Transparency Act Is Now Just for Foreign Reporting Companies
On March 21, 2025, FinCEN released an interim final rule (IFR) removing the requirement for U.S. companies and U.S. persons to submit beneficial ownership information (BOI) reports under the Corporate Transparency Act (CTA).
Alerts
3.05.25
U.S. Treasury Department Announces Changes to the BOI Reporting Requirements Under the Corporate Transparency Act
On March 2, 2025, the Department of Treasury confirmed in a press release that it will not enforce any penalties or fines associated with the BOI reporting requirements under the existing regulatory deadlines. The Department of Treasury has indicated its intention to propose revisions to the BOI reporting requirements that will narrow the scope of the rule to affect only foreign reporting companies. Additionally, the Department of Treasury announced that it will not enforce any penalties or fines against U.S. citizens or domestic reporting companies after these new, anticipated rule changes take effect.
Alerts
2.24.25
The Corporate Transparency Act is Back On–Again!
On February 18, 2025, the U.S. District Court for the Eastern District of Texas granted the federal government’s motion for a stay pending appeal and lifted the nationwide preliminary injunction in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.).
Alerts
12.30.24
On Again, Off Again – The Corporate Transparency Act is Off Again!
On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated its previous order granting a stay of the nationwide preliminary injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 24-40792 (5th Cir.). This order reinstates the nationwide preliminary injunction and once again temporarily enjoins enforcement of the Corporate Transparency Act (CTA) and the Beneficial Ownership Information (BOI) reporting requirements. The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) confirmed in its subsequent statement that “reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force.”
Alerts
12.10.24
Corporate Transparency Act: Nationwide Preliminary Injunction on Appeal
On December 3, 2024, a Texas federal district court judge in Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex., Dec. 3, 2024) issued a nationwide preliminary injunction temporarily enjoining enforcement of the Corporate Transparency Act (CTA) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (FinCEN) regulations on Beneficial Ownership Information Reporting Requirements (BOI Reporting Requirements). In a public statement over the weekend, FinCEN confirmed that it will comply with the nationwide preliminary injunction and Reporting Companies (generally, entities created or registered to do business in any state or tribal jurisdiction by filing a document with a secretary of state or other similar office) are not required to file BOI reports while the injunction remains in effect. FinCEN noted, however, that Reporting Companies can continue to submit voluntary BOI reports.
Alerts
12.05.24
Texas Federal Court Issues Preliminary Injunction, Temporarily Halting Enforcement of the Corporate Transparency Act and Its Beneficial Ownership Information Reporting Requirements
On December 3, 2024, a Texas federal district court judge in Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex., Dec. 3, 2024) issued a preliminary injunction nationwide temporarily halting enforcement of the Corporate Transparency Act (CTA) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (FinCEN) regulations on Beneficial Ownership Information Reporting Requirements (BOI Reporting Requirements). FinCEN’s BOI Reporting Requirements went into effect on January 1, 2024, and require Reporting Companies to file a report with FinCEN that includes information about the Reporting Company, its Beneficial Owners, and its Company Applicants (BOI Report).
Alerts
10.08.24
Important Filing Deadline: The U.S. Corporate Transparency Act
As we approach the final quarter of 2024, we wanted to remind you of the rapidly approaching deadline for the new Beneficial Ownership Information (BOI) reporting requirements under the U.S. Corporate Transparency Act (CTA). As of this month, it is estimated that roughly four million of the expected 32.6 million reporting companies have submitted their initial BOI reports. As such, we expect a flurry of filings in the coming months as non-exempt companies formed or registered in the U.S. prior to January 1, 2024, have until January 1, 2025, to file their initial BOI reports. Please contact your attorney at Wilson Sonsini for more information on compliance with these BOI reporting requirements.