Corporate Transparency Act Filing Requirement Returns

After a rollercoaster of stays and appeals, the Corporate Transparency Act (CTA) requirement that reporting companies file beneficial ownership information (BOI) has been reinstated with modified deadlines. 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., 6:24-cv-00336 (E.D. Tex.) stayed its January 7, 2025 order that temporarily blocked enforcement of the Financial Crimes Enforcement Network (FinCen) reporting requirements. In response to the reporting requirements’ reinstatement, FinCEN issued a notice stating that it would extend the deadline to file an initial, updated, and/or corrected BOI report to March 21, 2025, for most reporting companies. If a reporting company was previously given a deadline that is later than March 21, 2025, the later deadline remains in effect. FinCEN also indicated that it would provide an update explaining any additional deadline modifications in advance of the March deadline that reporting companies should look for in the coming weeks.