The Corporate Transparency Act (CTA) is back in effect and most Reporting Companies now have until March 21, 2025, to comply.
On February 18, 2025, the United States District Court for the Eastern District of Texas, Tyler Division, granted the Government’s motion to stay a nationwide preliminary injunction barring enforcement of the Reporting Rule of the Corporate Transparency Act (CTA). In effect, the February 18th order revives the CTA, and Reporting Companies are now required to comply with its requirements.
On February 19, the Financial Crimes Enforcement Network (FinCEN) issued guidance (located here) stating that the new deadline to file initial, updated, and/or corrected Beneficial Ownership Information Reports is now March 21, 2025. Moreover, in that guidance, FinCEN stated it will begin the process of reviewing and revising the BOI Reporting Rule to lessen the burden on lower-risk entities, including many small businesses. The extent and effect of these revisions is still unclear.
In addition, on February 11, 2025, the United States House of Representatives passed H.R. 736. If passed by the United States Senate and signed into law by the President, this bill would extend the reporting deadline for companies formed prior to January 1, 2024, until January 1, 2026. H.R. 736 was referred to the Senate Banking, Housing, and Urban Affairs Committee on February 11, 2025. Importantly, this bill would not extend the deadline for companies formed after January 1, 2024.
Woods Aitken will continue to closely monitor the status of the CTA and provide key updates as they become available. If you have any specific questions, please do not hesitate to reach out to your contact at Woods Aitken, or one of the following:
William A. Ozaki (Lincoln): wozaki@woodsaitken.com or (402) 817-4860
Daniel R. Carnahan (Omaha): dcarnahan@woodsaitken.com or (402) 898-7430
Lena A. Lucas (Denver): llucas@woodsaitken.com or (303) 606-6707