As we previously reported, on January 7, 2025, a second Federal District Court in Texas imposed a nationwide preliminary injunction on enforcement of the Corporate Transparency Act (CTA) in the case of Smith v. U.S. Department of Treasury. That injunction was stayed (lifted) by the same court on February 18, 2025. In a notice dated February 18, 2025, FinCEN confirmed the applicability of the CTA reporting requirements and extended the CTA reporting deadline to March 21, 2025.
Accordingly, non-exempt reporting companies are once again required to file their CTA Beneficial Ownership Information Reports with FinCEN by March 21, 2025.
If your company has not yet filed its CTA report and is not exempt from filing, we recommend that you complete your CTA Beneficial Ownership Information filing as soon as possible, in order to avoid late filing penalties.
Note that the U.S. House of Representatives unanimously passed a bill to delay the effective date of the CTA to January 1, 2026, but only for reporting companies formed before January 1, 2024. The Senate has not yet taken up this bill. We will advise you if and when this bill becomes law.
If you have any questions, please contact Edmund G. Kauntz at [email protected] or Nathaniel D. Tucker at [email protected] or via telephone at 216-292-5807.
