UPDATE, MARCH 3, 2025 — As was reported on Twitter/X Sunday, the Treasury Department will not enforce the Corporate Transparency Act's Beneficial Ownership Information reporting requirement. See this article from Entrepreneur for the latest and what small businesses need to know. The prior update and our article are below.
As of February 28, 2025, and shortly after this update (below) was written, it seems that FinCEN will not enforce penalties "for now, until a new interim rule is in place..." — according to Carol Roth (@caroljsroth on Twitter/X). Ms. Roth is a small business advocate and expert, an investor, and author of "You Will Own Nothing."
Her post, based on information from S-Corp.org, mentions that the interim rule is expected to extend reporting deadlines and that FinCEN intends to "solicit public comments on possible revisions to reporting."
Reminder: The latest information will appear on the FinCEN.gov website.
A Texas Federal District Court has stayed the enforcement of the Corporate Transparency Act (CTA):
Corporate Transparency Act – Recent Activity
A Texas district court stayed the nationwide order against enforcing the CTA, pending the government's appeal to the Fifth Circuit. The law and its regulations have been on hold since December due to court injunctions.
Judge Jeremy D. Kernodle of the U.S. District Court for the Eastern District of Texas stayed key regulations of the CTA in the Smith case, following a similar injunction in the McHenry case by another Texas judge.
The Supreme Court lifted the injunction in the Texas Top Cop Shop case on Jan. 23, prompting the government to request a stay in the Smith case, which Judge Kernodle granted on Feb. 17.
FinCEN extended the deadline for most companies to Feb. 19, 2025. It is assessing options to modify the deadline while focusing on entities posing national security risks. Plans include revising the BOI reporting rule to ease burdens on lower-risk entities, like U.S. small businesses.
Updated BOI Reporting Deadline: March 21, 2025
Updated deadlines require reporting companies to file initial, updated, or corrected BOI reports by March 21, 2025, with potential modifications before that date. Companies with later deadlines must adhere to their specific timeline.
The U.S. House of Representatives unanimously voted to extend the reporting deadline to Jan. 1, 2026. The measure awaits Senate consideration.
The U.S. Court of Appeals for the Fifth Circuit is set to hear oral arguments on April 1 in the Texas Top Cop Shop case.
See also our prior post on the topic, from January 13, 2025.
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