Sandy K. Baruah President and Chief Executive Officer at Detroit Regional Chamber | Twitter Website
Sandy K. Baruah President and Chief Executive Officer at Detroit Regional Chamber | Twitter Website
On February 18, 2025, the U.S. District Court for the Eastern District of Texas lifted its nationwide injunction against the enforcement of the Corporate Transparency Act (CTA). This action reactivates the CTA reporting requirements.
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) responded by extending the deadline for most reporting companies by 30 days to March 21, 2025. Companies with disaster relief extensions to April 2025 should adhere to their original deadlines. There is no longer a distinction in deadlines between companies formed before or after January 1, 2024.
During this extension period, FinCEN will evaluate potential further changes to deadlines and focus on prioritizing reports from entities that pose higher national security risks. FinCEN also plans to amend the Beneficial Ownership Information (BOI) reporting rule later this year to alleviate administrative burdens on lower-risk businesses, including many small U.S. businesses.
However, it remains uncertain if any amendments will be made before March 21, 2025.
The CTA reporting requirements are effective again. Companies without significant business or privacy concerns are encouraged to submit their filings promptly. Those with concerns should prepare materials for submission closer to the deadline if no updates occur.
The new deadline for companies is March 21, 2025 unless they have a later deadline due to specific circumstances.
Background information highlights that on December 3, 2024, an injunction was issued in Texas Top Cop Shop, Inc., et al. v. Merrick Garland et al., which was lifted by Supreme Court order on January 23, 2025. A second injunction in Smith v. U.S. Department of the Treasury was lifted on February 18, leading to the reinstatement of CTA requirements as there are no remaining nationwide injunctions in effect at present. The Department of Justice has appealed this decision but until resolved, CTA enforcement continues unimpeded except against plaintiffs in National Small Business United v. Yellen.
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