CORPORATE TRANSPARENCY ACT UPDATE: Treasury Department Suspends Enforcement of CTA for U.S. Companies, Announces Upcoming Rule Changes

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Corporate Transparency Act Update: Treasury Department Suspends Enforcement of CTA for U.S. Companies and Announces Upcoming Rule Changes

Published: March 6, 2025

by Jeanne L. Vance, Josh P. Concepcion

On March 2, 2025, the U.S. Department of the Treasury announced a major shift in its approach to the Corporate Transparency Act (“CTA”). The Treasury Department stated that it will not enforce any penalties or fines related to the CTA’s reporting requirements against U.S. citizens, domestic reporting companies, or their beneficial owners, both under the current deadlines and after forthcoming rule changes take effect. Additionally, the Treasury Department has indicated that it plans to issue a proposed rule that would limit the CTA’s reach to foreign reporting companies only. At this stage, however, no formal rule change has been enacted which means that the original compliance dates and penalties are still current law.

Corporate Transparency Act Update: Nationwide Injunction Still in Place – No BOI Filings Required for Now

Published: January 29, 2025

by Josh P. Concepcion

In a significant update regarding the enforcement of the Corporate Transparency Act (CTA), the Financial Crimes Enforcement Network (FinCEN) has confirmed that companies are not required to file Beneficial Ownership Information (BOI) reports at this time due to an outstanding nationwide injunction. However, reporting companies may continue to voluntarily submit BOI reports.

U.S. Supreme Court Lifts Injunction on Corporate Transparency Act Enforcement; Organizations Obligated to Make BOI Reports

Published: January 24, 2025

by Jeanne L. Vance, Josh P. Concepcion

The Supreme Court of the United States has stayed the nationwide injunction against enforcement of the Corporate Transparency Act (CTA), allowing the government to resume implementation of the law while litigation continues. Therefore, organizations are again required to make beneficial ownership interest reports to the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN).

Corporate Transparency Act Enforcement Faces Legal Challenges: Compliance Deadlines in Flux; No Current Mandatory Reporting Obligation Currently in Place

Published: January 6, 2025

by Jeanne L. Vance, Josh P. Concepcion

The Fifth Circuit ordered that a nationwide injunction be restored against enforcement of mandatory reporting obligations under the Corporate Transparency Act (CTA) on December 26, 2024. This means that any beneficial interest reporting by entities at this point is voluntary.

Court Blocks Nationwide Injunction of the Corporate Transparency Act: Fifth Circuit Grants Stay Pending Appeal; Compliance Period Briefly Extended

Published: December 24, 2024

by Jeanne L. Vance, Josh P. Concepcion

On December 23, 2024, the Fifth Circuit Court of Appeals granted the government’s emergency motion for a stay, effectively blocking a nationwide injunction issued by a district court against the Corporate Transparency Act (CTA) and its corresponding Reporting Rule. While this decision preserves the CTA’s reporting requirements, the Financial Crimes Enforcement Network (FinCEN) has extended the compliance reporting deadline to January 13, 2025, giving entities a brief window to file their reports while appellate litigation continues. Businesses are encouraged to work with deliberate speed to meet this deadline.

Corporate Transparency Act Reporting Enforcement and January 1 Deadline Blocked Nationwide by Texas Court

Published: December 4, 2024

On Tuesday, December 3, 2024, a federal District Court in the Eastern District of Texas issued a national preliminary injunction that enjoined the federal government from enforcing the Corporate Transparency Act (CTA) beneficial ownership interest reporting requirements, including the January 1, 2025 deadline, on companies formed prior to January 1, 2024:  Texas Top Cop Shop, Inc. v. Garland, E.D. Texas, No. 4:24-CV-00478, December 3, 2024. 

The issuance of national preliminary injunctions is controversial, a fact acknowledged by the Texas court in its opinion.  We expect the decision to be reviewed quickly by the U.S. Court of Appeals for the Fifth Circuit and, depending on how that appellate court rules, possibly by the U.S. Supreme Court. At the time of this update, the United States Treasury Department has not issued a statement about the Texas decision.  We expect additional legal developments on this subject in the very near future.  We will continue to update our clients on this matter if they have signed up to receive CTA updates here.

Disclosure Obligations Never Cease for California Healthcare Providers: A Roundup of Recent Legal Developments

Published: October 7, 2024

by Jeanne L. Vance
Healthcare Legal Updates

Corporate Transparency Act Updates as Compliance Deadline Looms; Longer Disclosure Period and Public Hearing Now Required for Maternity/Psych Unit Closures; and California Governor Vetoes Healthcare Transaction AG Approval Process for Private Equity Transactions

As we move into the fourth quarter of 2024, there are a flurry of breaking news items that relate to healthcare provider government disclosure obligations for healthcare providers. Weintraub shareholder Jeanne Vance outlines a few of them here.

FinCen Reporting Deadlines for 2024: Formed Companies and Other CTA Updates

Published: April 25, 2024

The month of April marks four months in the realm of the new Corporate Transparency Act, signifying deadlines for companies formed this year to adhere to the 90-day window for filing their beneficial ownership reports with the Financial Crimes Enforcement Network (“FinCEN”).  For companies formed in January, those deadlines are the month.