Corporate Transparency Act is Back

After going back and forth over the last few months, the Corporate Transparency Act (CTA) is now enforceable again – at least for now.

On February 5, the Government filed an appeal with the U.S. Fifth Circuit Court of Appeals on the preliminary injunction that was previously granted to stop enforceability of the CTA.  While that appeal is still pending, on February 18, 2025, the U.S. District Court for the Eastern District of Texas granted FinCEN a stay order on its previously issued preliminary nationwide injunction. As a result of this stay/pause on the injunction, BOI reporting requirements are now mandatory – for now at least.

FinCEN has just issued guidance that clarified the new filing deadlines – https://fincen.gov/boi:

1. For most reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025.
2. Reporting companies formed or registered on or after February 18, 2025, must file within 30 days from the date of creation or registration.
3. Reporting companies previously provided with extended deadlines due to disaster relief should follow the later deadlines

There are a number of ongoing litigations in federal courts throughout the United States challenging the enforceability of the CTA.

DISCLAIMER: The information provided above is for informational purposes only, is general in nature, and is not meant to be an exhaustive list of all reporting requirements under the CTA.  It does not constitute legal advice and should not be interpreted or relied on as such. For legal advice tailored to your specific circumstance, please reach out to one of our qualified attorneys.