Corporate Transparency Act Reinstated – New Deadline for Compliance

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Enforcement of the Corporate Transparency Act (the “CTA”) is once again in effect after a recent court decision. The new deadline for compliance is March 21, 2025 for most reporting companies, subject to any further guidance.

On February 18, 2025, a U.S. District Court for the Eastern District of Texas, Tyler Division, stayed a nationwide injunction against enforcement of the CTA it had previously issued in Smith v. United States Department of the Treasury.

In response to the stay of the Smith injunction, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) promptly issued an alert titled “Ongoing Litigation . . . Corporate Transparency Act reporting requirements back in effect” on its website,  in which it stated that the new deadline for filing any required initial, updated, and/or corrected beneficial ownership information reports (“BOIRs”) is March 21, 2025, unless the reporting company was previously given a later deadline.

FinCEN also indicated that it continues to assess its options to further modify deadlines.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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