CTA Reporting Requirements Back in Effect

On February 18, 2025, the U.S. District Court for the Eastern District of Texas issued a decision in Smith, et al. v. U.S. Department of the Treasury, et al., reinstating the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA). As a result, businesses are now obligated to file an initial, updated and/or corrected BOI report by March 21, 2025. For information on the initial suspension of the CTA, see our previous alerts HERE:

What This Means for Your Business?

• Mandatory Filing Deadlines: For the vast majority of reporting companies, the new deadline to file is March 21, 2025.
• Specific Extensions: Reporting companies that were previously given a reporting deadline later than March 21, 2025 have until the later deadline to report their initial BOI report.
• Exemptions: Plaintiffs in National Small Business United v. Yellen are not currently required to report their BOI.

Due to potential civil and criminal penalties for failure to file, business owners should consult with legal counsel to ensure compliance by analyzing their entity ownership and filing obligations.

If you have questions or concerns regarding these changes, contact Jason Lederman at jlederman@steinadlerlaw.com or 917.639.5121.