Corporate Transparency Act Reporting Reinstated (Again)

On February 18, 2025, the U.S. District Court for the Eastern District of Texas in the case of Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336, ordered that the nationwide preliminary injunction (which we noted in our February 2025 Sidebar) against enforcement of the beneficial ownership reporting requirements under the Corporate Transparency Act (the “CTA”) had to be lifted. Accordingly, any reporting company under the CTA is, once again, required to report information about its beneficial owners to the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).

Following the decision, FinCEN released a statement on its website that provides additional time for certain reporting companies to submit their initial reports, as follows:

• 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.
• Reporting companies that were previously given a reporting deadline later than the March 21, 2025 deadline must file their initial BOI report by that later deadline. For example, if a company’s reporting deadline is in April 2025 because it qualifies for certain disaster relief extensions, it should follow the April deadline, not the March deadline.

While these developments are important for reporting companies, they do not constitute the conclusion of the legal challenges to the CTA in the pending federal court cases. In the meantime, entities must now undertake the analyses required to determine their reporting requirements under the CTA and promptly file their reports ahead of the applicable deadline. The attorneys at Poole Shaffery would be happy to assist you with your CTA analyses and filings.