Practice Groups

Teeple Hall, LLP is a boutique law firm based in San Diego, California, committed to delivering exceptional and tailored legal services addressing a range of complex issues and requirements. The Firm has a long and distinguished history serving high net-worth individuals and families, entrepreneurs, privately owned businesses, and institutions throughout Southern California and around the world.

For over 25 years, the Firm has diligently addressed the unique needs of a diverse client base with an unwavering commitment to our guiding principle—to provide a depth and level of service traditionally associated with large, multi-office, multi-national law firms, in a boutique, highly personalized environment where lasting relationships are valued, cultivated and sustained.

Melding our attorneys’ depth of expertise and knowledge of the law together with a global perspective on business, tax, and private client matters, Teeple Hall, LLP has gained a strong reputation as a go-to firm for difficult and challenging cases on a breadth of matters. Our Practice Groups are comprised of Private Client, Corporate & Transactional, Tax, International, and Litigation. While Teeple Hall, LLP is positioned as a full-service law firm with the capability to address a wide array of legal issues, we have developed and enjoy a strong, global reputation for our leadership and work in our Private Client, Tax, and International Groups.

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UPDATE AS OF FEBRUARY 19, 2025: CTA BACK IN EFFECT – NEW DUE DATE OF MARCH 21, 2025 FOR MOST REPORTING COMPANIES

Dated February 19, 2025 On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed the nationwide injunction against the CTA in the matter ofcSmith, et al. v. United States Department of The Treasury, et al., described in prior posts below. Since this was the last remaining active injunction against the CTA, this stay means that the CTA and its reporting requirements are once again in effect. Non-exempt reporting companies are required to submit their initial BOI reports to FinCEN by March 21, 2025. Limited exceptions apply for reporting companies that qualify for certain disaster relief extensions provided by FinCEN. In recent statements, FinCEN has indicated that it may modify the reporting requirements of the CTA to “reduce regulatory burdens on businesses.” However, until any definitive modifications are announced, reporting companies should continue to submit BOI reports using the CTA’s current reporting requirements.
UPDATE AS OF JANUARY 23, 2025: U.S. SUPREME COURT RULING ON STAY OF NATIONAL INJUNCTION IN THE MATTER OF TEXAS TOP COP SHOP, INC., ET AL. V. MCHENRY, ET AL. (FORMERLY TEXAS TOP COP SHOP, INC., ET AL. V. GARLAND, ET AL.)

Dated January 23, 2025 On January 23, 2025, the U.S. Supreme Court released its ruling regarding a stay of injunction in the matter of Texas Top Cop Shop, Inc., et al. v. McHenry, et al. (described in previous posts as Texas Top Cop Shop, Inc., et al. v. Garland, et al.). The Court determined that the national injunction previously upheld by the “merits panel” of the Federal Appellate Court must be lifted until the matter is fully adjudicated on appeal. Oral hearings for this matter are scheduled to begin on March 25, 2025. However, as of this date, the CTA and its reporting requirements remain unenforceable. In the matter of Smith, et al. v. United States Department of The Treasury, et al. (described below), a nationwide injunction remains in effect, meaning the CTA and its reporting requirements remain unenforceable for all reporting companies throughout the country. The Department of Justice, on behalf of the Department of Treasury, has not yet filed an appeal in this matter, though one is expected in the coming days. For now, the CTA and its reporting requirements remain unenforceable, though reporting companies may voluntarily submit BOI reports to FinCEN.
UPDATE AS OF JANUARY 7, 2025: 2ND NATIONAL INJUNCTION ENACTED BY U.S. DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS

Dated January 7, 2025 On January 7, 2025, the U.S. District Court for the Eastern District of Texas in the matter of Smith, et al. v. U.S. Department of Treasury, et al. ruled that the CTA was likely unconstitutional, concluding that the CTA and its reporting requirements could not be enforced by the Financial Crimes Enforcement Network (“FinCEN”) and instituting a nationwide injunction. This is the 2nd case in recent weeks from the U.S. District Court for the Eastern District of Texas to come to this conclusion and to enact a nationwide injunction, the first matter being Texas Top Cop Shop, Inc., et al v. Garland, et al.
UPDATE AS OF DECEMBER 26, 2024: “MERITS PANEL” OF THE US COURT OF APPEALS OF THE FIFTH DISTRICT RULING

Dated December 27, 2024 On December 26, 2024, a “merits panel” of the US Court of Appeals of the Fifth District reevaluated the earlier December 23, 2024 decision of the US Court of Appeals of the Fifth District in the case of Texas Top Cop Shop, Inc. v. Garland and reinstated the stay of the nationwide preliminary injunction on the CTA that had been removed on December 23, 2024. This means that the CTA and its reporting requirements are currently unenforceable pending the final decision of the US Court of Appeals of the Fifth District, albeit such a decision may also be appealed and brought to the US Supreme Court for adjudication. The US Court of Appeals of the Fifth District has scheduled oral arguments for this case to begin on March 25, 2025. On December 27, 2024, FinCEN released a statement on www.FinCEN.gov/boi stating that the CTA shall not be enforceable until the appeal is decided by the US Court of Appeals of the Fifth District and that Reporting Companies are not subject to liability while the stay remains in place.
UPDATE AS OF DECEMBER 3, 2024: US DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS RULING

Dated December 23, 2024 On December 3, 2024, the US District Court for the Eastern District of Texas in the case of Texas Top Cop Shop, Inc. v. Garland ruled that the CTA was likely unconstitutional, concluding that the CTA and its reporting requirements could not be enforced by the Financial Crimes Enforcement Network (“FinCEN”). However, the Department of the Treasury appealed this ruling, and on December 23, 2024, the US Court of Appeals of the Fifth District granted a stay of the District Court’s preliminary injunction, pending the outcome of the Department of the Treasury’s appeal. The effect of this decision is that all non-exempt Reporting Companies are required by law to submit beneficial ownership information (“BOI”) reports to FinCEN. Certain extensions have been granted by FinCEN to accommodate certain Reporting Companies. The reporting deadline for Reporting Companies created before January 1, 2024 has been extended to Monday, January 13, 2025.
UPDATE AS OF MARCH 12, 2024: CTA RULING IN U.S. DISTRICT COURT OF NORTHERN DISTRICT OF ALABAMA

Dated March 12, 2024 On March 1, 2024, in Nat’l Small Bus. United v. Yellen, No. 22-cv-1448 (N.D. Ala. Mar. 1, 2024), ECF No. 51, the U.S. District Court of the Northern District of Alabama ruled that the CTA is unconstitutional and cannot be enforced against the plaintiffs of the case, the members of the National Small Business Association (“NSBA”) as of March 1, 2024. On March 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), the agency tasked with enforcing the CTA, released a statement declaring that it intends to respect the terms of such ruling but will continue to enforce the reporting requirements of the CTA for all other entities, meaning all qualifying entities that were not members of the NSBA as of March 1, 2024, stating, “reporting companies are still required to comply with the law and file beneficial ownership reports as provided in FinCEN’s regulations.” Additionally, on March 11, 2024, the Department of Justice, on behalf of the Department of the Treasury (of which FinCEN is a branch), filed an appeal against the ruling, meaning a federal appellate court will review and rule on the case at some point in the future. Reporting Companies not directly associated with this ruling should continue to prepare to comply with the reporting requirements of the CTA within the appropriate timeframes.
UPDATE AS OF JANUARY 26, 2024: INCREASED MONETARY CIVIL PENALTY FOR CTA NONCOMPLIANCE

Dated January 26, 2024 On January 25, 2024, FinCEN increased the maximum civil monetary penalty for beneficial ownership information violations from $500 per day to $591 per day. Although this was done to account for inflation, the more severe civil penalty underscores the importance of accurately and timely filing BOI Reports, including proactively filing updated BOI Reports, when necessary.

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