Corporate Transparency Act – Has the Roller Coaster Ride Ended Or is it Just Reloading?

  1. Supreme Court Ruling and Reporting Deadline: On February 18, 2025, a federal judge in Texas lifted the injunction that had previously blocked the enforcement of the CTA. Consequently, the Financial Crimes Enforcement Network (FinCEN) has reinstated the reporting requirements, setting a new filing deadline of March 21, 2025, for most companies to submit their beneficial ownership information (BOI) reports. 
  2. Pending Legislation (H.R. 736): The U.S. House of Representatives unanimously passed H.R. 736, the “Protect Small Businesses From Excessive Paperwork Act of 2025,” which proposes extending the BOI reporting deadline to January 1, 2026, for entities formed before January 1, 2024. This bill is currently awaiting approval in the Senate. 
  3. Entities Required to File: The CTA mandates that corporations, limited liability companies (LLCs), and other similar entities (Trusts, IRAs, LPs, etc.) disclose their beneficial owners. 
  4. How to Report: Entities required to file must submit their BOI reports through FinCEN’s online portal. Detailed instructions and the reporting portal are available on FinCEN’s official website. 

Important Note: While the proposed legislation may extend the deadline, as of now, the enforceable deadline remains March 21, 2025. Entities should prepare to comply by this date unless an official extension is enacted.

For more detailed information and to access the reporting portal, please visit FinCEN’s official BOI filing page or our previous articles on the subject: 

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