Written by: Aaron E. Kacer and Steven T. Lawrence After more than a year of regulatory changes, court decisions, suspensions, reinstatements, and revised guidance, the CTA appears to have reached a significant milestone. For many domestic businesses, the uncertainty surrounding beneficial ownership reporting may finally be coming to an end (at least for now). …
CORPORATE TRANSPARENCY ACT UPDATE As we near the end of the first quarter of 2026, the CTA continues to generate confusion. Over the past year, business news headlines were flooded with the CTA articles at a rapid pace – from “CTA Reinstatement” to “CTA Enjoined,” “CTA Suspended,” and “New Interim Final Rule” – as a…
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…
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…
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…
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…
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