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.
Executive Order Accelerates Federal Cannabis Rescheduling and Expands Medical Marijuana and Cannabinoid Research
On December 18, 2025, President Donald Trump signed an Executive Order titled Increasing Medical Marijuana and Cannabidiol Research, marking the most consequential federal cannabis policy action in decades. While the Order does not legalize marijuana or immediately alter its status under federal law, it directs the administration to complete the long-anticipated rescheduling of cannabis under […]
Strict Compliance Is Necessary: NJ Public Bidding Dispute Offers Lessons for Public Entities and Contractors
In ML, Inc. v. Edison Township Board of Education, the New Jersey Appellate Division reinforced the discretion of public entities to draft and enforce timing requirements as to the dates of key bid forms that are required to be submitted with public bids. The court upheld the Edison Township Board of Education’s decision to award a […]
NJDEP Reproposes All Appropriate Inquiry (AAI) Due Diligence Discharge Reporting Rule: Key Implications
On November 17, 2025, the New Jersey Department of Environmental Protection (NJDEP) changed its previously proposed rule which would have required persons conducting All Appropriate Inquiry (AAI)(due diligence) at real properties to report any discharge of contamination discovered during the due diligence to NJDEP and the record owner of the property. NJDEP has now changed […]
Federal Cannabis Rescheduling: Status, Impacts, and Strategies
Recent reports indicate that President Trump is preparing to issue an executive order as early as Monday, December 15 directing his administration to finalize the long-anticipated reclassification of cannabis under the federal Controlled Substances Act (CSA) from Schedule I to Schedule III. This development follows years of regulatory review and political debate spanning multiple administrations […]
EPA's Landmark WOTUS Proposal and the Mandate of Sackett v. EPA
EPA Proposes Historic WOTUS Rule—A Major Victory for Predictability, Cost Savings, and Development Efficiency, Driven by the Supreme Court’s Sackett Ruling On November 20, 2025, the U.S. Environmental Protection Agency (EPA) and the Army Corps of Engineers published a Proposed Rule (Document 90 FR 52498) to redefine the “Waters of the United States” (WOTUS) in […]
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 […]
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