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.
- Tom Hong (Atlanta/Austin/Charlotte)
- Brett Lockwood (Atlanta/Austin/Charlotte)
- Eric Breitman (New York/Washington D.C.)
- Ken Crane (Chicago)
- Adam Buss (Jacksonville/Miami/Tampa)
- Peter Rho (Los Angeles)
- Ben Graham-Evans (London)
- Michael Kraus (Atlanta – German Practice)
- Stefan Buske (Munich)
- Nicola Fiordalisi (Milan – Italian Practice)
To read more about the CTA, CLICK HERE.
***Updated as of February 20, 2025