Corporate Transparency Act - Reporting Requirements Are Back in Effect

Legal Alert

CTA

The reporting obligations for filing Beneficial Ownership Information Reports under the Corporate Transparency Act are officially back in effect. On February 18, 2025, the United States District Court for the Eastern District of Texas granted the United States Department of the Treasury’s appeal for a stay of the court’s order granting a nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (CTA) in Smith v. U.S. Department of the Treasury. As this ruling lifted the only remaining national injunction on the enforceability of the CTA, FinCEN has stated that Beneficial Ownership Information (BOI) reporting requirements under the CTA are in effect once again.

Specifically, in its recent alert on February 19, 2025, FinCEN stated that it is extending the BOI filing deadlines by 30 days, and that it will assess its options to further modify deadlines and reporting rules. Regarding the new deadline for most reporting companies, it specifically notes the following:

“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.”

Unless or until FinCEN revises the current deadline or there are other legal or legislative developments, Reporting Companies that have not filed a BOI Report as of February 19, 2025, and are not exempt from the CTA’s reporting requirements, should prepare to file their BOI Reports by the March 21, 2025 deadline.

We are following the developments relating to Smith v. U.S. Department of the Treasury, and plan to provide further updates as the case develops. If you have any questions related to the CTA, the recent rulings, or bill please reach out to your SGR attorney or any of the individuals listed below.

To read more about the CTA, CLICK HERE.

***Updated as of February 20, 2025

Related Professionals

Related Capabilities

Media Contact

Public Relations Contact
Kate Lenders
Senior Marketing Manager
klenders@sgrlaw.com
312-360-6478

Jump to Page

Smith, Gambrell & Russell, LLP Cookie Preference Center

Your Privacy

When you visit our website, we use cookies on your browser to collect information. The information collected might relate to you, your preferences, or your device, and is mostly used to make the site work as you expect it to and to provide a more personalized web experience. For more information about how we use Cookies, please see our Privacy Policy.

Strictly Necessary Cookies

Always Active

Necessary cookies enable core functionality such as security, network management, and accessibility. These cookies may only be disabled by changing your browser settings, but this may affect how the website functions.

Functional Cookies

Always Active

Some functions of the site require remembering user choices, for example your cookie preference, or keyword search highlighting. These do not store any personal information.

Form Submissions

Always Active

When submitting your data, for example on a contact form or event registration, a cookie might be used to monitor the state of your submission across pages.

Performance Cookies

Performance cookies help us improve our website by collecting and reporting information on its usage. We access and process information from these cookies at an aggregate level.

Powered by Firmseek