The Wicked Witch Has Been Resurrected – The Corporate Transparency Act is Back

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The Corporate Transparency Act (CTA) is back on again…for now

On Feb. 18, a Texas district court lifted the last remaining nationwide block against enforcing the Corporate Transparency Act (CTA), restoring beneficial ownership information (BOI) reporting requirements. The Beneficial Ownership Information (BOI) Reporting Deadline is Now March 21, 2025.

WHAT YOU SHOULD DO:
You can go to the Financial Crimes Enforcement Network site (FinCEN site) and submit the requested information on the Beneficial Owners of any corporations or LLCs you have, subject to 23 exceptions, such as medical organizations and other licensed organizations listed here.

However, we are suggesting to our clients they do nothing for another week.

This is because, earlier this year, on Feb. 10, the U.S. House of Representatives voted 408-0 to postpone the CTA’s reporting deadline to Jan. 1, 2026. The measure is now pending in the Senate. Given the unanimous vote in the House and the back-and-forth of enforcement and compliance dates, we believe the Senate will also pass this so that there will be more time to comply.

We will follow the status of the extension in the Senate and gather other information. Next week, we will send an email sharing what we have learned with you. Should it be necessary to file, we will provide instructions on accessing the FinCEN site and registering.
For those unaware, Congress passed the BOI reporting requirement in 2021 as an anti-money laundering initiative to prevent the misuse of corporations and limited liability companies for criminal gain. However, various judges have blocked implementation several times, claiming the CTA’s reporting requirements represent a direct challenge to state authority over corporate governance.

https://www.coomberconsulting.com/

Skip Ralph Coomber, III
Employer Tax Benefits Consultant
Your Trusted Advisor
Cal. State Bar No.: 150701
U.S. Tax Court Bar No.: CR25430
Coomber Consulting, LLC
M: 858-354-3910