FinCEN announced an interim final rule on March 21, 2025 that removes both United States companies, regardless of ownership, and United States persons from the definition of Reporting Companies required to file a Corporate Transparency Act Beneficial Ownership Information (“BOI”) Report . Under the new rule, “Reporting Company” means only those entities “that are formed
The Financial Crimes Enforcement Network (“FinCEN”) announced on February 27, 2025 that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (“BOI”) reports.
For most businesses, Beneficial Ownership Information (“BOI”) reports will now be due by March 21, 2025 according to a FinCEN Notice updating deadlines for filing BOI reports.
The last nationwide injunction against enforcement of the Corporate Transparency Act’s Beneficial Ownership Information (“BOI”) reporting requirements has been stayed by Judge Kernodle of the Eastern District of Texas.
The United States House of Representatives unanimously passed the Protect Small Businesses from Excessive Paperwork Act on February 10, 2025, which would grant a one-year extension to file Beneficial Ownership Information (“BOI”) Reports under the Corporate Transparency Act.
On February 6, 2025, the Financial Crimes Enforcement Network (“FinCEN”) published an alert announcing that it has filed a Notice of Appeal in Smith v. U.S. Department of the Treasury, which enjoined the enforcement of Beneficial Ownership Information (“BOI”) Reporting requirements nationwide.
The Supreme Court of the United States stayed a nationwide injunction on January 23, 2025 in McHenry v. Texas Top Cop Shop, Inc. The Financial Crimes Enforcement Network (“FinCEN”) will now be allowed to enforce the filing requirements of the Corporate Transparency Act while the matter is pending in lower courts, meaning any business originally required to file BOI reports before January 1, 2025 must comply immediately.
Another judge with the Eastern District of Texas enjoined enforcement of the Beneficial Ownership Information reporting requirements on Wednesday January 8, 2025.
The Department of Justice won’t give up. Today, the Department of Justice filed an emergency writ asking the Supreme Court to suspend the nationwide preliminary injunction holding the Corporate Transparency Act (“CTA”) unconstitutional and to allow enforcement of the act and its Beneficial Ownership Information filings until the final resolution of the case. This request
The U.S. Fifth Circuit Court of Appeals reinstated the injunction against enforcement of the Beneficial Ownership Information reporting requirements.