File Your CTA Beneficial Ownership Report with FinCEN on or prior to March 21, 2025
As of February 18, 2025, FinCEN filing obligations under the Corporate Transparency Act (CTA) are required. The nationwide injunction previously imposed by the U.S. District Court for the Eastern District of Texas, Smith v. U.S. Department of the Treasury, has been lifted by that court. By changing course, the Texas court allowed CTA to move forward and filing beneficial ownership information reports (BOI reports) is no longer voluntary.
Entities subject to CTA must file initial, updated, or corrected BOI reports on or prior to Friday, March 21, 2025. FinCEN may further modify or extend this deadline.
Going forward, other deadlines may impact your entity including:
| Event: | Filing Deadline for BOI Report: |
|---|---|
| For any entity formed or registered on or after January 1, 2025 | Within 30 days of formation/registration |
| Duty to update previously filed BOI reports | Within 30 days of any changes |
This continues to be a developing story, and we expect that it will change in the near future. As we’ve learned with CTA, there are many challenges in various courts as well as pending legislation before the U.S. Congress. We expect that this recent development will not be the last update by FinCEN. The contents of this Client Alert are for informational purposes only and do not constitute legal advice. If you have any questions or want to engage our Firm to provide CTA compliance services, please contact a Baird Holm attorney.
For historical background information on the CTA please see our previously published articles:
The Corporate Transparency Act – What You Need to Know Now (January 3, 2024)
Your Health Care Organization Could Be Subject to the Corporate Transparency Act (CTA) (February 29, 2024)
What is Happening with the Corporate Transparency ACT (CTA)? (December 5, 2024)
Well, That was Quick – The Corporate Transparency Act is Back: Appellate Court Lifts Nationwide Injunction (December 23, 2024)
Update: CTA Filing Extended to January 13, 2025 for Entities Formed Prior to 2024 (December 24, 2024)
Hold Your Horses, 5th Circuit… Let’s Figure Out What’s Happening with the Corporate Transparency Act (December 27, 2024).
Did the January 23rd U.S. Supreme Court Stay Change Your Filing Obligations with the Corporate Transparency Act? (January 24, 2025)
