After months of litigation, the Corporate Transparency Act (“CTA”) is once again effective, and most companies subject to the CTA are required to file Beneficial Ownership Information (“BOI”) reports with the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) on or before March 21, 2025.
Earlier in February, we reported on the status of two injunctions involving the CTA. On December 3, 2024, the United States District Court for the Eastern District of Texas issued a preliminary injunction prohibiting the enforcement of the CTA (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas Top Cop Shop v. Garland). The Texas Top Cop Shop injunction was stayed by the U.S. Supreme Court on January 24, 2025.
A separate injunction against the enforcement of the CTA's reporting rules was issued by a different judge of the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Department of the Treasury on January 7, 2025, prior to the Supreme Court’s decision. The Supreme Court’s decision did not affect the injunction issued by the U.S. District Court for the Eastern District of Texas in the Smith case. However, on February 5, 2025, the U.S. Department of Justice filed a notice of appeal of the district court’s order in the Smith case and, in parallel, requested a stay of the order during the appeal. On February 18, 2025, the U.S. District Court agreed to stay its January 7, 2025, order until the appeal is completed.
Now that the CTA reporting requirements are back in effect, the vast majority of companies subject to the CTA are required to file an initial, updated, and/or corrected BOI report on or before March 21, 2025. 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.
