The U.S. District Court for the Eastern District of Texas has lifted the injunction in Samantha Smith v. U.S. Department of the Treasury, reinstating enforcement of the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements. As a result, reporting companies must once again comply with BOI filing requirements.
Updated Filing Deadlines
- March 21, 2025: This is the new deadline for the vast majority of reporting companies to file their initial, updated, and/or corrected BOI reports. FinCEN has stated that it will provide further updates if this deadline changes.
- Later Deadlines for Disaster Relief: Companies that previously received extensions due to disaster relief—such as those impacted by Hurricanes Debby, Helene, and Milton—should adhere to their original extended deadlines, even if they fall after March 21, 2025.
- Exemptions: Certain plaintiffs in National Small Business United v. Yellen, including Isaac Winkles and associated entities, are currently not required to report their BOI.
What This Means for Businesses
The reinstatement of reporting requirements underscores the importance of prompt action. To stay compliant:
- Prepare Your Documentation: Ensure your beneficial ownership information is accurate, complete, and organized.
- Submit Reports Promptly: Use FinCEN’s E-Filing system to submit reports at boiefiling.fincen.gov.
- Stay Informed: Monitor FinCEN updates and court proceedings, as further changes may affect future deadlines.
Important Reminder
Rivero, Gordimer & Company does not provide assistance with CTA compliance matters. However, we strongly encourage businesses to work with knowledgeable advisors to ensure compliance readiness in this dynamic environment.
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