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A federal district court in Texas issued a preliminary nationwide injunction on December 3, 2024, blocking the Corporate Transparency Act (CTA) and its associated regulations, which require U.S. business entities to report beneficial ownership information to the Treasury Department.

The injunction was granted by Judge Amos L. Mazzant III of the U.S. District Court for the Eastern District of Texas in response to a lawsuit filed by Texas Top Cop Shop Inc., a family-owned business in Texas, along with other businesses and the Libertarian Party of Mississippi. The plaintiffs argued that the CTA exceeds Congress’s authority to regulate interstate and foreign commerce by imposing requirements on incorporated entities, regardless of whether they engage in commercial activities.

Under the CTA, most small businesses were required to disclose their beneficial owners to the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) by January 1, 2025. The government contended that the law was essential to combatting anonymous shell companies and preventing money laundering, terrorism financing, and other illicit activities, asserting that it fell within Congress’s constitutional powers.

However, the court ruled that while Congress may regulate corporate activity, the Commerce Clause does not extend to requiring the disclosure of information for law enforcement purposes, rendering the CTA unconstitutional in this regard.

“The Court determines that the injunction should apply nationwide. Both the CTA and the Reporting Rule apply nationwide, to ‘approximately 32.6 million existing reporting companies.’ . . . [a]s the Government states, the Court cannot provide Plaintiffs with meaningful relief without, in effect, enjoining  the  CTA  and  Reporting  Rule  nationwide.  The  extent  of  the  constitutional  violation Plaintiffs have shown is best served through a nationwide injunction.”

It is too soon to know yet how FINCEN will respond and whether or not deadlines to file will be extended as a result of this injunction. We will update with further guidance as it becomes available.

For further questions regarding the update, contact Liskow attorneys Leon Rittenberg III, Julie Chauvin, Marilyn Maloney, Caroline Lafourcade or Kevin Naccari, Jr. and visit our Tax Practice page.

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On July 4, 2025, the President of the United States signed the One Big Beautiful Bill (the “Bill”), which included significant taxing and spending modifications. To pay for extending certain tax cuts and other changes, the bill adds an Adjusted Gross Income (“AGI”) floor for charitable contribution deductions for both individuals and corporations.

The Bill applies a 0.5% of AGI floor on itemized deductions by individuals, which works separately from the AGI ceiling on deductible contributions for individuals. Contributions above the limitation may be carried forward for five years, but any amounts disallowed below the floor may only be carried forward if the aggregate corporate contributions exceed the individual’s AGI limitation, including the disallowed amounts. The limitation for individual contributions to most charities remains at 50% of AGI, and the Bill extended the 60% limitation for cash contributions originally found in the TCJA.

There is an additional aggregate limitation for individual taxpayers on all itemized deductions equal to the dollar amount at which the 37% rate bracket begins for such taxpayer. This new limitation will also take effect for the 2026 tax year.

The bill also applies a 1% of AGI floor on charitable contribution deductions for corporations, which also operates separately from the 10% AGI limitation of charitable contribution deductions. The same carryforward rule for individuals applies to corporations exceeding the 10% limitation. The changes for both individuals and corporations will not take effect until the 2026 tax year. Because the changes do not take effect until next year, there may be an incentive to engage in charitable giving planning before the end of this year.

For further questions regarding the bill, contact Liskow attorneys Caroline Lafourcade, Bob Angelico, John Rouchell, Leon Rittenberg III and Kevin Naccari and visit our Tax practice page.

On July 4th, President Donald J. Trump signed the “One Big Beautiful Bill Act”, H.R. 1, 119th Cong., just one day after the House passed it on a 218-214 vote.

The bill permanently extends the 2017 Tax Cuts and Jobs Act’s individual tax provisions that were set to expire at the end of the year, such as the lower individual income tax rates and a larger standard deduction. It also raises the cap on the state and local tax deduction from $10,000 to $40,000.

The legislation also makes permanent a series of business tax breaks covering interest expensing, research and development spending and bonus depreciation of certain assets, including machinery and factories.

The legislation also fulfills several campaign pledges Trump made during the 2024 presidential race, including provisions to eliminate taxes on tip income and overtime pay for certain workers and a new deduction for seniors. The bill also includes a deduction for car loan interest payments.

As a result, some workers will receive an extra tax break through 2028.

Employees who work in jobs that traditionally receive tips could deduct up to $25,000 in tip income from their federal income taxes, while workers who receive overtime could deduct up to $12,500 of that extra pay subject to income limitations.

In addition, the legislation phases out most of the clean energy tax credits introduced in the Inflation Reduction Act, enacted during former President Biden’s presidency.

The $7,500 consumer tax credit for electric vehicles is eliminated for purchases made after Sept. 30, 2025.

The Act increases the estate tax exemption from $13.99 million to $15 million for individuals and from $27.98 million to $30 million for a married couple for 2026.

Significant changes to Section 1202 of the Internal Revenue Code excluding gain from sales of qualified small business stock (QSBS) are contained in the One Big Beautiful Act encouraging investment in start-up companies.  The enhancements to this tax incentive include raising thresholds and allowing investors to enjoy its tax benefits in as little as three years with a tiered exclusion based on the applicable holding period. Taxpayers should consider whether there are any advantages to postponing the issuance of QSBS until after the effective date of the Act or whether there are planning opportunities by selling such stock prior to the effective date.

Lastly, it has been reported that in anticipation of the bill’s enactment, Treasury and the IRS have already assembled teams to address implementation of the new provisions. To no one’s surprise, it seems that most of these provisions will have limitations and restrictions on applicability.

For further questions regarding the bill, contact Liskow attorneys Caroline Lafourcade, Bob Angelico, John Rouchell, Leon Rittenberg and Kevin Naccari and visit our Tax practice page.

Governor Jeff Landry signed Act 384 into law on June 20, 2025, making changes to the sales and use tax provisions of the revised statutes. Included in the changes was an amendment to Section 305.1 of Title 47, which provides an exemption for certain vessel-related supplies and services. The ships and ships’ supplies exemption has for decades exempted ship construction, materials and goods used in the repair of vessels, and goods and materials used in the operation and maintenance of vessels from both state and parish sales and use taxes.

Specifically, the Act adds “software” to the list of items not subject to sales and use tax when incorporated into a vessel constructed in Louisiana, if it becomes a component part of the vessel. The Act also adds “software” to the list of materials exempt from sales and use tax when used or consumed in the maintenance and operation of the vessel. A similar exemption was added for “software” that becomes a component part of a vessel when used in repairs to such vessel.

Finally, the changes included an exemption for “digital products, prewritten computer software access services, and information services purchased by the owners or operators of vessels operating exclusively in foreign or interstate coastwise commerce, where the digital product or service is used in the maintenance or operation of the vessel” and is required to operate the vessel or obtain certain regulatory clearances.

The changes also clean up some of the language in the statute by applying these exemptions to vessels and then defining vessel under this section. For purposes of Sectio 305.1, a vessel means “a ship, vessel, or barge, including a commercial fishing vessel, drilling ship, or drilling barge.” Act 384 continues the Governor’s initiative to revise the state’s taxing statutes, which began last year in the Third Extraordinary Session of the Louisiana Legislature.

For further updates regarding this topic, contact Liskow attorneys Bob Angelico,  Leon Rittenberg III, Caroline Lafourcade, and Kevin Naccari, Jr. and visit our Tax practice page.