Update: FinCEN Limits the Scope of the CTA Reporting Requirements

As suggested by our recent trail of client alerts, the Corporate Transparency Act (“CTA”) has been the center of controversy, with back and forth rule making and litigation focusing on the Act’s beneficial ownership information (“BOI”) reporting requirements. Please see our client alert from November 5, 2024 for basic information about the CTA filing requirements and the penalties for failing to comply. Our most recent update from March 11, 2025, covered the U.S. Treasury Department’s announcement declaring that they would not enforce any penalties or fines associated with the BOI reporting rule against U.S. citizens, domestic reporting companies, or their […]

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Update: CTA Saga Continues

As we reported in our client alert from November 5, 2024, the 2021 Corporate Transparency Act (“CTA”) requires “reporting companies” to file beneficial ownership information (“BOI”) with the Financial Crimes Enforcement Network (“FinCEN”). There has been a relentless back and forth of rulemaking and litigation efforts initiated last year to halt enforcement of the CTA, as indicated in our previous alert of February 20, 2025. The CTA has civil and criminal penalties for failure to comply, including fines of up to $10,000 and imprisonment of up to 2 years. Or, to be more precise, the CTA used to have these […]

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