Notification

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an Interim Final Rule which serves as an update to reporting requirements under the Corporate Transparency Act (“CTA”). The update revised the definition of “reporting company” to only include entities formed under the laws of a foreign country AND that are registered to do business in the United States. Additionally, U.S. persons that beneficially own foreign entities do not need to report under the CTA. This update removed U.S. entities from the definition of “reporting companies,” removing any obligation of U.S. entities to file beneficial ownership reports under the […]

On February 17, 2025, in the case of Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex), the U.S. District Court for the Eastern District of Texas, Tyler Division issued an order granting the U.S. Department of the Treasury’s motion to stay the January 7, 2025 nationwide injunction of reporting requirements under the Corporate Transparency Act (“CTA”) pending appeal. This order marks an end to the final standing injunction blocking enforcement of reporting requirements under the CTA by the Financial Crime Enforcement Network (“FinCEN”). On February 19, 2025, FinCEN posted an update addressing the reinstatement […]

On January 23, 2025, the Supreme Court of the United States (SCOTUS) granted the Application for Stay filed by the government, led by Justice Alito—Justice Gorsuch concurring and Justice Jackson dissenting. This Grant of Stay marks an end to the December 5, 2024 injunction preventing the Financial Crimes Enforcement Network (FinCEN) from enforcing the Corporate Transparency Act (CTA) issued by the United States District Court for the Eastern District of Texas, in Texas Top Cop Shop, Inc. v. McHenry, case No. 4:24–cv–478 (formerly Texas Top Cop Shop v. Garland) pending the appeal in the United States Court of Appeals for […]

As of December 27, 2024, reporting requirements under the Corporate Transparency Act (CTA) are once again paused after a panel of the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the December 23, 2024, order granting a stay of the preliminary injunction. The past week has been tumultuous for thousands of small businesses following the status of Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex.) to determine whether they will be required to file their beneficial ownership information as required by the CTA. For anyone not actively following the […]

Due to a recent federal court order, reporting companies are not currently required to file beneficial ownership information under the Corporate Transparency Act while the order is in place. However, reporting companies may continue to voluntarily submit beneficial ownership information reports and should monitor the status of the court order going forward. More information is available on FinCEN’s website at https://www.fincen.gov/boi. If you have any questions, please email us at CTA@gentrylocke.com.

Dear Gentry Locke Clients: This letter is to notify you of a significant change in federal law that will impact nearly everyone operating a business through a legal entity such as a corporation, limited liability company, limited partnership or other similar entity. The Corporate Transparency Act (the “CTA”) became effective on January 1, 2024, and all required companies should be prepared to comply with the new reporting requirements. The CTA requires specific private companies that meet the CTA criteria of a “reporting company” (“Reporting Company”) to file informational reports with the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) […]