CORPORATE TRANSPARENCY ACT

New Federal Rule: Reporting Beneficial Owners for U.S. Entities

Effective January 1, 2024, the U.S. Corporate Transparency Act (CTA) requires certain entities created or registered to do business in the United States to report information about their beneficial owners, senior officers, and control persons to the U.S. Treasury Department, unless an exemption is available. The reporting requirement (i) is currently applicable to entities newly created or registered to do business on or after January 1, 2024, and (ii) takes effect on January 1, 2025, for reporting companies that were created or registered to do business before January 1, 2024.

The Treasury Department has provided some guidance, often in the form of “frequently asked questions” (FAQs), on the reporting obligations and exemptions from reporting that may be available. While these FAQs are helpful, there are still areas where application of the CTA, or the FAQs, is unclear and requires application of legal judgment.

We continue to monitor closely developments related to the implementation of beneficial ownership information reporting requirements under the CTA. Our multidisciplinary taskforce would be pleased to discuss their application to the facts and circumstances of any particular legal entity and/or ownership structure within your organization.

Essential Insights

Insights

Client Alerts

FinCEN Issues Interim Final Rule – BOI Reporting Obligations Narrowed to Foreign Reporting Companies and New Deadlines Issued

As we previously discussed and in alignment with the U.S. Treasury Department’s previous announcement, on March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that dramatically narrows the reporting requirements for beneficial ownership information (“BOI”) under the Corporate Transparency Act (“CTA”).

March 27, 2025 • V&E CTA Update

March 27, 2025 • 2-minute read

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Client Alerts

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Katherine Frank, Robert Kimball, and Christopher Rowley examine the rising appeal of Texas as a jurisdiction for U.S. corporations, comparing it to Delaware’s established dominance in corporate law.

March 17, 2025 • Published by The Transatlantic Law Journal

March 17, 2025 • 1-minute read

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Client Alerts

FinCEN and the U.S. Treasury Department Suspend CTA Enforcement – Forthcoming Rule to Narrow CTA Compliance to Foreign Reporting Companies and Extend Deadlines

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”).

March 6, 2025 • V&E CTA Update

March 6, 2025 • 2-minute read

Treasury Releases Application for Loans to Businesses Critical to Maintaining National Security Background Decorative Image

Client Alerts

Corporate Transparency Act: Once Again Enforceable – New Compliance Dates Apply

As we previously discussed, on January 7, 2025, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction delaying the implementation of the Corporate Transparency Act’s (“CTA”) reporting requirements (Smith, et al. v. U.S. Department of the Treasury).

February 21, 2025 • V&E CTA Update

February 21, 2025 • 2-minute read

Treasury Releases Application for Loans to Businesses Critical to Maintaining National Security Background Decorative Image