FinCEN Corporate Transparency Act filings shut down by the US District Court for the Eastern District of Texas
Under the Corporate Transparency Act (CTA), entities that were in existence before January 1, 2024 are required to file Beneficial Owner Reports (BOR) with the Financial Crimes Enforcement Network (FinCEN) before January 1, 2025. Requirements also exist that set forth the time frame for filing the report when a new entity is formed. On December 3, 2024, an injunction was issued by a federal court that applies nationwide. Under the injunction, no company may be held liable for failing to file a BOR. The federal government has appealed, and we are following all developments very closely. If you navigate to the FinCEN site, you will find the following:
BOI e-Filing Alert: Please note that beneficial ownership information reporting requirements have been affected by a recent federal court order. The Department of the Treasury is appealing that order. In the meantime, reporting companies are not currently required to file a BOIR and are not subject to liability if they fail to do so while the applicable order remains in force.
However, reporting companies may still opt to file a BOIR.
The net result is that FOR NOW, entities are not required to file BORs and will not be penalized for failing to file while the injunction is in effect. If the government is successful, new filing date requirements will be put into effect. If the district court ruling stands and survives future challenges, the CTA FinCEN filing requirements never get resurrected. Watch for future updates.
NJ Contractors and Developers Eligible for Sales Tax Exemption for Affordable Housing Projects
New Jersey developers and contractors may now benefit from the NJ sales tax exemption for contractors under a new law designed to support the construction and improvement of affordable housing projects. P.L. 2024, c.3 (effective May 1, 2024) expands an existing sales tax exemption to include contractors working for “housing sponsors engaged in affordable housing […]
The Federal Redefinition of Hemp Under H.R. 5371 – Compliance, Risk Mitigation, Strategic Repositioning, and Political and Legislative Considerations
The enactment of the Continuing Appropriations and Extensions Act (H.R. 5371) on November 12, 2025, has fundamentally altered the legal foundation of the U.S. hemp industry. Embedded within this omnibus spending measure are revisions to the Agricultural Marketing Act of 1946, which itself was amended by the Agriculture Improvement Act of 2018 (the 2018 Farm […]
New Jersey Energy Security and Affordability Act: What Senate Bill S4876 Means for Nuclear and Grid Development
Senate Bill S4876, the “New Jersey Energy Security and Affordability Act,” was introduced on November 17, 2025, by Senators Bob Smith and John Burzichelli. The bill establishes a comprehensive regulatory structure designed to support the development of advanced nuclear generation, expand distributed energy storage, and implement statewide demand-reduction programs. The bill cites rising electricity demand – […]
New Obligations for NY LLCs Under the 2026 LLC Transparency Act
New York is preparing to roll out its own version of beneficial ownership reporting—and it arrives sooner than many businesses realize. Beginning January 1, 2026, the New York LLC Transparency Act (LLCTA) will impose new filing obligations on all New York LLCs and foreign LLCs authorized to do business in the state. While the LLCTA […]
Federal Hemp Ban Signed Into Law: Enforcement Timeline, Impacts, and Strategies
On November 12, 2025 the President signed the Continuing Appropriations, Agriculture, Legislative Branch, Military Construction and Veterans Affairs, and Extensions Act, 2026 (H.R. 5371) into law. Embedded within this legislation are amendments that fundamentally redefine “hemp” under federal law and close the regulatory gap that has permitted delta-8, delta-10, THCA, HHC, THC-O, and similar products […]
FinCEN's New Real Estate Report Requirements to Take Effect March 1, 2026
What is the FinCEN Real Estate Report? New FinCEN reporting requirements combat money laundering through real estate transfers. These requirements apply to certain residential real estate transfers. They begin on March 1, 2026. Similar to Corporate Transparency Act reporting requirements, these new FinCEN rules aim to increase transparency and combat financial crimes in real estate […]
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