On February 18, 2025, the U.S. District Court for the Eastern District of Texas issued a decision in Smith, et al. v. U.S. Department of the Treasury, et al. that has brought the Corporate Transparency Act (CTA) reporting requirements back into effect. This development brings important obligations and considerations for business owners across the United States.
Current Reporting Deadlines
FinCEN has established the following deadline structure:
- March 21, 2025: New filing deadline for most reporting companies
- Extended Deadlines Remain Valid: Companies with previously granted extensions (such as disaster relief) should adhere to their original later deadlines
- Potential Updates: FinCEN may announce further deadline modifications before March 21
Important Developments
The Department of the Treasury recognizes that businesses need adequate time to comply with BOI reporting obligations. Several key developments are worth noting:
- Rule Revision Plans: FinCEN intends to initiate a process this year to revise the BOI reporting rule, specifically aimed at reducing burden for lower-risk entities, including many U.S. small businesses.
- Free Filing System: Reporting companies can submit their beneficial ownership information directly to FinCEN at no cost using the E-Filing system at boiefiling.fincen.gov.
- Notable Exemptions: Certain parties are currently exempt from reporting requirements, including:
- Plaintiffs in National Small Business United v. Yellen
- Members of the National Small Business Association (as of March 1, 2024)
- Isaac Winkles and his related reporting companies
What Should Business Owners Do Now?
- Review Your Status: Determine if your business is a reporting company and whether any exemptions apply.
- Prepare Required Information: If you need to file, begin gathering your beneficial ownership information.
- Monitor for Updates: Stay attentive to potential deadline modifications or rule changes from FinCEN.
- Plan for Filing: Familiarize yourself with FinCEN’s E-Filing system at boiefiling.fincen.gov.
Looking Ahead
While the reporting requirements are currently in effect, FinCEN’s commitment to reducing regulatory burden on businesses suggests that changes may be coming. The agency is particularly focused on easing requirements for lower-risk entities while maintaining focus on national security priorities.
Need Assistance?
Our team stays current with these evolving requirements and can help you understand your obligations. Contact us to discuss your specific situation and ensure compliance with current requirements.
This post is for informational purposes only and does not constitute legal advice. Please consult with qualified legal counsel regarding your specific situation.
