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CTA and BOI filing uncertainty continues

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The saga of the Corporate Transparency Act and its beneficial ownership information reporting requirement goes on.

When the District Court for the Northern District of Alabama ruled that the CTA was unconstitutional on March 1, 2024, it specified that the ruling only applied to the 65,000 members of the plaintiff organization, the National Small Business Association. 

But on Dec. 3, another court, the District Court for the Eastern District of Texas, granted a nationwide preliminary injunction prohibiting the federal government from enforcing the CTA and its reporting rule entirely. The injunction, ruled the court, applies against enforcement of the CTA and its Jan. 1, 2025 filing deadline. The Department of Justice appealed the injunction two days later, on Dec. 5, 2024.

Treasury Department building

Picasa/rrodrickbeiler – Fotolia

Beginning Jan. 1, 2024, the CTA imposed a requirement to file beneficial ownership information with the Treasury’s Financial Crimes Enforcement Network, or FinCEN. Existing companies were required to file within the year 2024, while a new company started during 2024 would have 30 days (temporarily extended to 90 days for 2024 only) to file. An estimated 32.6 million filings were expected during 2024, with five to six million expected each following year. The penalty for failure to comply is $500, with a cap of $10,000. 

A beneficial owner is one who directly or indirectly exercises substantial control over the reporting entity, or who directly or indirectly owns or controls 25% or more of the ownership interests of the reporting entity.

“We always thought that a delay was necessary in the filing requirement,” said Roger Harris, president of Padgett Business Services. “That’s because of issues with the 30-day rule and lack of guidance on substantial ownership.”

“We’re telling our people to continue to gather the information necessary to file the report, but to inform clients of where we are regarding the court injunction,” he continued. “We will wait until we get further information from FinCEN and DOJ before we file a report unless the client tells us to go ahead and file. What I hope we hear is that FinCEN believes it will take too long to resolve all the court cases and the outstanding issues about how the current program is being implemented, and will extend the deadline for one year to Jan. 12, 2026.”

“The problem with the order is that it doesn’t talk about any remedies about what will happen once the injunction is lifted or an appellate court says it was wrongly decided,” said attorney Michael Chua. “It doesn’t say that the deadline is automatically extended for one year if the injunction disappears. Technically speaking, those deadlines are still effective. That’s the biggest concern at this point, since it doesn’t provide any remedies — it’s kind of a head-scratcher.”

As of right now, there is no obligation or duty to file, observed Earl Melamed, a partner and head of the CTA Working Group at law firm Neal, Gerber & Eisenberg. 

But the penalties are onerous and are likely to catch people unaware, he said, so companies may not want to ignore the requirement entirely. 

“We suggest that our clients can pause from any filing that they otherwise might make, but that they should continue to assemble the information so that they are ready to file,” said Melamed. “The requirement can be reimposed at any date — the Texas district court did not decide that the CTA was unconstitutional, they merely said that it was ‘likely’ to be found to be unconstitutional. The appellate court could lift the injunction but say that the deadlines are extended for a year; they could provide more time to file but they don’t have to.” 

Melamed believes the DOJ will fight very hard to have the injunction lifted. But given the fact there are a number of cases before different courts around the country seeking to overturn the CTA on constitutional grounds, the question may eventually go before the Supreme Court.  

“If there are two conflicting rulings, that’s the ticket to the Supreme Court,” he said.

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Accounting

Continuous Auditing Transforms Corporate ERPs

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continuous auditing transforms corporate erps

As corporate accounting departments cross the threshold into late July 2026, the adoption of continuous, automated auditing systems has reached a definitive turning point. Driven by advances in artificial intelligence and deep integration with modern Enterprise Resource Planning (ERP) platforms, leading finance organizations are moving away from traditional, periodic post-hoc audits in favor of real-time, 100% transactional verification. This technological transition is redefining internal control environments, reducing compliance costs, and eliminating the structural delays inherent in legacy quarterly closing processes.

Unlike traditional auditing frameworks that rely on statistical sampling—a process that inevitably leaves operational blind spots—continuous auditing software monitors operational data feeds continuously. Every purchase order, electronic invoice, payroll disbursement, and cross-border wire transfer is automatically cross-referenced against established corporate governance parameters, regulatory tax schedules, and anti-fraud algorithms in real time. Anomalies or unauthorized ledger entries are flagged instantly, allowing internal audit teams to investigate and remediate compliance gaps immediately rather than months after the close of a financial period.

The implications for executive financial management are far-reaching. By embedding continuous verification directly into daily transaction workflows, chief financial officers gain uninterrupted visibility into the organization’s true financial standing. Real-time balance sheet auditing eliminates the severe operational bottlenecks associated with month-end and quarter-end financial reconciliations, freeing accounting professionals to focus on strategic financial modeling, tax planning, and capital allocation rather than manual data entry and spreadsheet consolidation.

However, implementing continuous auditing requires accounting leadership to invest heavily in data governance and technical upskilling. Internal audit teams must evolve from manual ledger reviewers into system architects capable of auditing complex algorithms and validating automated data pipelines. Accounting firms and corporate controllers that master continuous auditing will establish a resilient compliance framework capable of meeting stringent international regulatory standards with total transparency.

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U.S. Imposes New 50% Tariffs on Canadian Imports Under Rare Legal Provision

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U.S. Imposes New 50% Tariffs on Canadian Imports Under Rare Legal Provision

WASHINGTON — In a major escalation of cross-border trade friction, U.S. President Donald Trump has signed executive orders imposing new 50% tariffs on a wide selection of Canadian exports, citing discriminatory practices by Ottawa targeting American auto, dairy, and beverage industries.

The new duties, announced Monday, will take effect in 30 days. They target a broad spectrum of consumer and industrial goods—ranging from wine, liquor, and milk products to commercial cement, furniture, clothing, and hockey equipment.

Untested Legal Mechanism

To enact the sweeping measures, the administration invoked Section 338 of the Tariff Act of 1930—a rarely used legal provision allowing the executive branch to levy additional tariffs of up to 50% on foreign nations deemed to discriminate against U.S. commerce.

White House officials noted that Section 338 addresses trade discrimination rather than national security or economic emergencies. The move comes months after prior global emergency tariffs faced legal challenges in domestic courts, signaling Washington’s pivot toward alternate statutory authorities to maintain import duties.

Senior administration officials briefed reporters that the measure directly responds to Canadian provincial bans on U.S. alcohol, restrictions on American vehicle exports, and import quota disparities affecting U.S. dairy and cheese producers relative to third-party trading partners.

“While the administration continues to secure reciprocal trade agreements globally, Canada retaliated against efforts to protect domestic industry,” U.S. Trade Representative Jamieson Greer stated.

USMCA Impact and Carve-Outs

Significantly, the newly ordered 50% duties will apply to designated items even if they otherwise comply with the United States-Mexico-Canada Agreement (USMCA).

However, the administration confirmed key targeted exemptions:

  • Energy products (including oil and natural gas)
  • Potash and critical minerals
  • Fish and seafood
  • Goods already governed by sector-specific duties (such as existing steel and aluminum tariffs)

Administration representatives emphasized that the tariffs do not stem from recent disputes concerning drifting Canadian wildfire smoke, noting that policy options regarding environmental spillover remain under separate review.

Canadian Response and Market Reaction

Following the White House announcement, the Canadian dollar experienced a sharp decline against the U.S. dollar, falling approximately 0.4% during evening trading.

Canadian Prime Minister Mark Carney issued a statement emphasizing that Canada’s earlier counter-duties had merely matched previous U.S. trade actions. “Canada stands ready to engage intensively to address outstanding issues with the U.S. to the mutual benefit of our citizens,” Carney stated, pointing to detailed proposals Ottawa submitted to modernize the USMCA framework.

Ontario Premier Doug Ford took a firmer stance, urging a “dollar-for-dollar” reciprocal response if the measures go into effect on August 19.

With a 30-day implementation window before the duties officially lock in, industry associations and trade groups on both sides of the border are calling for urgent bilateral negotiations to avert further supply chain disruption across North America.

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Accounting

Automated Continuous Auditing: Transforming Compliance and Real-Time Financial Oversight

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Transforming Compliance and Real-Time Financial Oversight

The traditional accounting paradigm—defined by periodic monthly closures and post-hoc annual audits—is rapidly giving way to continuous, automated financial oversight. As of July 2026, forward-thinking accounting practices and multinational corporate finance departments are leveraging continuous auditing systems powered by advanced machine learning models. These systems monitor operational transactions in real time, shifting audit methodologies from sample-based post-analysis to absolute, 100% transaction-level verification.

The operational advantages of continuous auditing are transformative. Standard auditing procedures historically relied on statistical sampling, which, despite rigorous methodology, inherently left gaps where anomalies or fraudulent transactions could go undetected for months. Modern continuous auditing platforms integrate directly with enterprise resource planning (ERP) databases, instantly cross-referencing purchase orders, invoices, bank feeds, and tax records. Any deviation from established control parameters or unusual transaction behavior triggers immediate flags for internal audit teams, dramatically reducing detection lag from quarters to seconds.

Beyond fraud prevention, continuous auditing fundamentally alters internal reporting and decision-making. Executive leadership no longer has to wait weeks after the close of a quarter to evaluate precise financial standing; real-time verified ledger data provides an uninterrupted view of operating margins, tax liabilities, and cash flow dynamics. This real-time visibility enables corporate controllers to adjust capital allocation strategies dynamically, mitigating liquidity constraints and capitalizing on emerging commercial opportunities far more efficiently than competitors bound to legacy reporting cycles.

However, implementing continuous auditing requires accounting professionals to acquire new analytical capabilities. The role of the auditor is evolving from manual data reconciliation toward system validation, algorithmic model governance, and strategic risk interpretation. Accounting firms and corporate finance departments must invest in continuous technical education, ensuring that audit staff possess the data engineering skills necessary to design, maintain, and evaluate complex automated compliance systems.

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