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Update: Corporate Transparency Act Reporting Requirement Back in Effect

Dan Collins

  585.231.1322

  dcollins@hselaw.com

Emily R. Day

  585.231.1391

  eday@hselaw.com

As of February 17, 2025, the District Court for the Eastern District of Texas in Smith, et al v. U.S. Department of Treasury, et al, the Court stayed its own injunction on the Corporate Transparency Act and beneficial ownership reporting. As such, FinCEN has reinforced the beneficial ownership information (“BOI”) reporting requirement for all existing reporting companies.

FinCEN has stated on its website that it intends to revise the BOI reporting requirement to reduce burden for lower-risk entities, such as U.S. small businesses. At this time, the deadline for existing reporting companies to file their BOI report is now March 21, 2025. For newly created reporting companies, the BOI report must be filed within 30 days of formation. We encourage all reporting companies to file the BOI report by the appropriate deadline to avoid any potential penalties and fines.

For more information on the CTA and its reporting requirements, please see HSE’s December 23, 2024 LEGALcurrents.

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