March 31, 2025
The Corporate Transparency Act (CTA) requires most small businesses to file a report identifying their Beneficial Ownership Information (BOI). Various entities were exempted from this requirement, including those in certain industries and those with more than 20 employees and $5 million in revenues. The original deadline to file was December 31, 2023, but that deadline was postponed to the end of 2024. In the period from December 2024 through March 2025, a flurry of court decisions and Treasury Department announcements resulted in the deadline being canceled and re-scheduled several times, sometimes only days apart.
On March 2 the Treasury Department announced that it was suspending enforcement of the reporting requirements with respect to all US persons and companies. The announcement also said that the Department would issue a proposed new rule to narrow enforcement of the CTA to apply only to foreign persons and entities. On March 21, the proposed new rule was published. It is now open for public comment for 60 days before final action can be taken. As a result, the Treasury Department is now telling US companies and persons that they are not required to file BOI reports…at least for now.
If you have any questions, please contact one of our attorneys at (574) 294-7491.