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With seven major changes in the past four months, staying on top of the enforceability requirements for the Corporate Transparency Act can be a difficult task and a major headache. Hilger Hammond experts Ron Reynolds and Jill K. Miller have been fastidiously tracking and analyzing these updates to provide real-time counsel to clients on how and when their companies should adapt. Below is an timeline of changes we've been following and their associated implications: December 3, 2024:?The U.S. District Court for the Eastern District of Texas issued a nationwide injunction, blocking the enforcement of the CTA. Implication:?This ruling suspended Beneficial Ownership Information Reporting (BOIR) compliance obligations for Reporting Companies under the CTA. December 23, 2024:?The Motions Panel of the U.S. Court of Appeals for the Fifth Circuit granted a stay of the District Court’s December 3, 2024 injunction.? Implication:?This stay reinstated the BOIR obligations, requiring Reporting Companies to comply with the CTA before a new January 13, 2025 deadline. December 26, 2024:?The Merits Panel of the Fifth Circuit vacated the December 23, 2024 stay issued by the motions panel. Implication:?The District Court’s December 3, 2024 injunction was reinstated, again suspending BOIR requirements indefinitely. January 7, 2025:?The U.S. District Court for the Northern District of Texas issued a second nationwide injunction enjoining the enforcement of the CTA. Implication:?This ruling further reinforced the suspension of BOIR compliance requirements. January 23, 2025:?The U.S. Supreme Court granted a stay on the December 3, 2024, injunction.? Implication:?While this lifted the first injunction, it did not affect the second nationwide injunction issued on January 7, 2025, and FinCEN was still prohibited from enforcing the BOIR requirements. February 27, 2025:?FinCEN announced that they would not issue fines or penalties in connection with BOI information reporting deadlines.? Implication:?FinCEN is looking into revising the reporting rules and intends to issue an interim final rule that extends BOI reporting deadlines. March 21, 2025:?FinCEN issued an interim final rule that recalibrates the CTA.? Implication:?The requirement for U.S. reporting companies and U.S. persons to report beneficial ownership information (BOI) is removed, and the definition of a "reporting company" is revised to mean only those entities that are formed under foreign law and have registered to do business in any U.S. state or Tribal jurisdiction. You can track these updates in real time on our blog (https://lnkd.in/dCXzkDjF) and/or sign up to our Legal Alerts email list (

Looking forward to presenting at this popular event with BHS Insurance and Doeren Mayhew. We hope you'll join us!

We had a blast participating in last night's West Michigan Construction Institute annual construction rally! And while the Hilger Hammond team didn't take home 1st place, we were able to hone our skills in tape measuring, paper airplane construction, and changing into PPE in a Porta Potty. A special shoutout to attorney/woodworker Andrew Hilger for his "Wheels of Justice" pine wood derby design. Most importantly, we were proud to be a part of raising funds to support the great work WMCI is doing to empower and employ the next generation of construction professionals. Thanks to all that participated and we look forward to next year's event! P.S. If you're interested in learning who the Rally champions were, here are the top 10 finishers: Champion: Triangle Associates 2nd Place: Architectural Metals Inc. 3rd Place: Plummer's Environmental Services, Inc. 4th Place: CarbonSix Construction 5th Place: The Bouma Corporation 6th Place (tied): EV Construction & Nederveld, Inc. 7th Place: Kent Companies 8th Place: MacAllister? Rentals 9th Place (tied): Hilger Hammond, Dan Vos Construction Company Inc., & Sobie Company Inc. 10th Place: DHE PLUMBING AND MECHANICAL

The Corporate Transparency Act reporting requirements are back in effect... again. As a result of the U.S. District Court’s (Smith v. U.S. Department of the Treasury, Eastern District of Texas) decision on February 18, 2025, staying the preliminary injunction pending appeal, beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect with a 30 day extension from February 19, 2025 (until March 21, 2025) for most companies. Follow the link below to learn what deadlines you should be paying attention to, the next steps from the Financial Crimes Enforcement Network (FinCEN), and how Hilger Hammond can help you navigate this ever-evolving issue. https://lnkd.in/gcFUndw4

Thanks to the Commercial Alliance of REALTORS for inviting us to come speak at their West Michigan lunch-n-learn today! We had a great group of real estate professionals in the room as Ben Hammond and Jill K. Miller shared a presentation with what may be our scariest (but important!) title yet: "How to Get Sued."

Whiplash Legal Update: Fifth Circuit Reinstates Nationwide Preliminary Injunction Against Enforcement of the CTA! If you're subscribed to the Hilger Hammond email list, you'll recall that a Texas U.S. District Court had entered the nationwide preliminary injunction on December 3, 2024. On December 23rd, the Fifth Circuit overruled the District Court and reinstated the requirements of the CTA. The US Department of the Treasury’s Financial Crimes Enforcement Network quickly released guidance which extended the filing deadlines from January 1, 2025, to January 13, 2025, or later depending on when your entity was created or registered. But then, in a head-spinning turn of events, the Fifth Circuit AGAIN reversed itself on December 26 and reinstated the nationwide preliminary injunction. Here's what happened: The initial decision reversing the District Court was entered by the Fifth Circuit’s “motions panel.” The case has now been assigned to a “merits panel,” the panel of judges who will decide the appeal. It was the “merits panel” that decided to reinstate the preliminary injunction “in order to preserve the constitutional status quo while the merits panel considers the parties’ weighty substantive arguments…” Here's What's Next: The merits panel issued an expedited briefing schedule and has scheduled oral argument on the case for March 25, 2025, at 10am. A conventional appeal process would lead to the presumption that no action is necessary until the Fifth Circuit rules on the appeal on or after March 25th. However, this matter has already defied conventional processes, and Hilger Hammond recommends that you prepare your filing so that you will be in a position to comply with the CTA reporting requirements should the Fifth Circuit reverse course again. Here's how Hilger Hammond Can Help: Hilger Hammond has several expert attorneys closely following how this case continues to evolve at a rapid pace. If you have any questions or need help in preparing your filing (if you have not already filed your required beneficial ownership reports), please contact attorneys Jill K. Miller or Ron Reynolds for assistance. https://lnkd.in/g2D9iqM9

Hilger Hammond Attorney Ron Reynolds was a panelist on a webinar put on by the Real Property Law Section of the State Bar of Michigan today entitled Eminent Domain: Ask the Experts. Ron and his fellow panelists discussed current trends in condemnation and inverse condemnation law and fielded questions from registrants on a variety of issues. Thanks to all that joined and to the State Bar for hosting the event! ? Ron is a past Chair of the State Bar Section and currently serves as a Co-Chair of its Eminent Domain Committee.

Legal Alert: Corporate Transparency Act Reporting Obligations Blocked Here's what happened: On December 3, 2024, the United States District Court for the Eastern District of Texas issued a nationwide preliminary injunction which prevents the United States Government from enforcing the Corporate Transparency Act (CTA). The CTA, which became effective January 1, 2024, would have imposed on all businesses burdensome disclosure requirements to the United States Department of Treasury by the end of 2024 unless the business met one of the narrow exemptions from the reporting obligations. The preliminary injunction modifies both the reporting obligations and stays the compliance deadline of January 1, 2025. The District Court ruled in a 79-page decision that the CTA falls outside the scope of powers granted to Congress under the Commerce Clause of the United States Constitution. The Court also stated that this “quasi-Orwellian statute” infringes upon powers held by the States under our federalist system of government. As such, the Court found a likelihood that the plaintiffs would ultimately prevail in the case. What's Next: Hilger Hammond has been counseling countless clients on compliance with the January 1, 2025, disclosure requirements. As a result of the preliminary injunction, businesses are not currently obligated to make these disclosures. There’s likely more to come. This decision could be upheld or reversed on appeal to the Fifth Circuit Court of Appeals and could include an appeal to the United States Supreme Court. While the Biden administration most certainly would appeal to the Fifth Circuit, it is unclear at this time how the change in administrations may alter the government’s continued litigation. Since this is a preliminary injunction, even if the decision is upheld on appeal there will likely be further litigation at the District Court to determine whether a permanent injunction should be issued. Hilger Hammond will continue to monitor the litigation and provide updates on the status of any appeal or in the event that this order is modified or changed. Please reach out to your Hilger Hammond attorneys Jill K. Miller or Ron Reynolds with any questions on how this could impact your business.

On November 15, 2024, a United States District Court in Texas blocked the Biden administration’s attempt to increase the salary threshold for employees exempt from overtime compensation. You can learn more about how this could impact your business and directly connect with Hilger Hammond legal experts in the article below:

Hilger Hammond is hiring! We're on the lookout for a dynamic, well-organized legal assistant with top-notch communication skills. You can learn more about the qualifications, responsibilities, benefits and compensation by following the link below: https://lnkd.in/gs2XMuGp