Corporate Transparency Act
Speer Law Office, LLC is here to assist legal entities (such as limited liability companies, corporations, etc.), with complying with the Corporate Transparency Act (“CTA”) that went into effect January 1, 2024.
UPDATES:
(March 21, 2025): FinCEN announced they have removed the CTA Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons. Only foreign companies are required to report.
(February 27, 2025): FinCEN announced they will not be issuing fines or penalties for failure to file or update Beneficial Ownership Information Reports (BOIRs) by the communicated deadlines. No later than March 21, 2025, FinCEN intends to issue an interim final rule that extends BOI reporting deadlines.
(February 18, 2025): FinCEN announced that reporting companies are once again required to file beneficial ownership reports. The deadline for initial reports has been extended from December 31, 2024 to March 21, 2025.
(January 24, 2025): FinCEN announced that reporting companies are still not required to file beneficial ownership reports, even with the U.S. Supreme Court’s order yesterday. However, reporting companies may voluntarily report.
(January 23, 2025): The U.S. Supreme Court granted the federal government’s request to pause the nationwide block on enforcing the CTA.
(December 26, 2024): The U.S. Court of Appeals has vacated its December 23, 2024 decision that reinstated the CTA and its Reporting Rule, so the CTA reporting requirement is once again on hold. Reporting companies may voluntarily report if they wish, but the reporting deadlines are not being enforced by FinCEN.
(December 23, 2024): The U.S. Court of Appeals has lifted the Texas district court’s injunction that suspended the CTA and its Reporting Rule. Therefore, the reporting requirements have been reinstated, and FinCEN has extended the filing deadline, so companies that were required to report by January 1, 2025, now have until January 13, 2025, to file their BOIR.
(December 7, 2024): FinCEN responded to the December 3rd injunction by posting an alert to the FinCEN website, stating that “reporting companies are not currently required to file their beneficial ownership information with FinCEN and will not be subject to liability if they fail to do so while the preliminary injunction remains in effect.” However, reporting companies may continue to submit beneficial ownership information reports (BOIR) voluntarily.
(December 5, 2024): The Department of Justice appealed the case above, indicating that the government will seek review of the Texas District Court’s order.
(December 3, 2024): A Texas district court issued a nationwide injunction, suspending the CTA and its Reporting Rule for now. Thus, at this time, companies are not required to complete the initial Beneficial Ownership Information Report (BOIR) filings, but they may choose to do so.
We will keep our website updated as new rulings regarding the CTA are issued.
For additional information about the CTA, please ‘click’ on the links below:
FinCEN, Beneficial Ownership Information Reporting Rule Fact Sheet,
https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet (Sept. 29, 2022)
FinCEN, Beneficial Ownership Information Reporting: Frequently Asked Questions,
https://www.fincen.gov/boi-faqs (issued Sept. 29, 2023)
FinCEN, Small Entity Compliance Guide, version 1.0,
https://www.fincen.gov/sites/default/files/shared/BOI_Small_Compliance_Guide_FINAL_Sept_508C.pdf
(Sept. 2023)