Corporate Transparency Act Update | File Your BOI
UPDATE
As of March 3, 2025: FinCEN announced that it will not enforce actions against any companies, including fines and penalties, that do not file or update BOI reports by the March 21 deadline.
While we cannot promise this will be the last update (unless or until 31 U.S.C. 5336 is repealed or amended by Congress, it is still a federal law.), we can share the Treasury’s March 2, 2025 press release:
The Treasury Department is announcing today that, with respect to the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either. The Treasury Department will further be issuing a proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only. Treasury takes this step in the interest of supporting hard-working American taxpayers and small businesses and ensuring that the rule is appropriately tailored to advance the public interest.
In addition to the press release issued by Treasury, a Federal judge in Grand Rapids recently struck down the CTA as unconstitutional. Both events seem to be evidence that the CTA is headed towards its demise, but thus far there never appear to be enough nails to keep the coffin shut on the CTA.
Previously …
Under the Corporate Transparency Act (CTA), reporting entities are, once again, required to file their Beneficial Ownership Information (BOI) by March 21, 2025.
On February 17, a federal judge revoked the stay he had issued on January 7, in Smith v. U.S. Department of the Treasury, 6:24-cv-00336 (E.D. Tex.), which had previously blocked the Government from enforcing the BOI Rule nationwide.
The next day, on February 18, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) announced the new deadline for submitting an initial, updated, or corrected BOI report to FinCEN: March 21, 2025.
What this means for you
Currently, any entity, including those formed before January 1, 2024, is required to report by March 21, 2025.
If FinCEN makes further changes, such as modifying the deadlines for entities that do not pose significant security risks or revising the BOI reporting rule, we will keep you informed.
Need to refresh your memory about this CTA saga? Check our our other blog post.
The CTA situation is continually evolving and our firm will continue to provide updates as they become available. If you require assistance with the process of compliance with the CTA, please Connect with Us.