Corporate Transparency Act: Reporting Obligations are Back in Effect
February 19, 2025
CORPORATE TRANSPARENCY ACT:
REPORTING OBLIGATIONS ARE BACK IN EFFECT
The beneficial ownership information reporting required by the Corporate Transparency Act, 31 USC § 5336 (the “Act”) has been put back into effect. Most “reporting companies” will have until March 21, 2025 to report with the Financial Crimes Enforcement Network (“FinCEN”). On February 18, 2025, the U.S. District Court for the Eastern District of Texas in Smith, et. al. v. U.S. Department of the Treasury, et. al., agreed to stay its January 7, 2025 order enjoining enforcement of the Act (citing the Supreme Court’s December 23, 2024 decision to stay the lower court’s injunction in the separate case of Texas Top Cop Shop, Inc., et al. v. Garland, et al.).
FinCEN has issued updated guidance as follows:
For the vast majority of reporting companies, the new deadline to file an initial, updated, and/ or corrected BOI report is now March 21, 2025. FinCEN will provide an update before then of any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided.
We will continue to monitor guidance provided by FinCEN and further developments in the above cases. Please reach out to us if there is a question about how the Act might impact you or your company, a company you anticipate forming, or need assistance filing a required report under the Act.