On February 18, 2025, the U.S. District Court for the Eastern District of Texas reinstated the FinCEN Corporate Transparency Act requirements by lifting the nationwide preliminary injunction. Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.). As of the date of this publication, all reporting companies must comply with the Corporate Transparency Act’s reporting requirements. FinCEN has released a statement (FIN-2025-CTA1) that requires most reporting companies to file an initial, updated, or corrected BOI report by March 21, 2025. For reporting companies that were previously given a reporting deadline later than the March 21, 2025, deadline, they must file their initial BOI report by that later deadline. This would include any entities that were formed after February 19, 2025, or reporting companies that qualified for certain disaster relief extensions. FinCEN states that it will assess its options to further modify deadlines while prioritizing reporting for those entities that pose the most significant national security risks.
Visit https://fincen.gov/ for additional updates.
JAH Can Help
If you have any questions regarding the reinstated Corporate Transparency Act reporting requirements, contact a member of our Corporate & Non-profit Practice Group or watch our CTA explainer video.
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