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⚠️ CTA Reporting Rule Update – Legal Battle & New Deadlines! ⚠️

The Corporate Transparency Act (CTA) Beneficial Ownership Information (BOI) Reporting Rule is back in play, but the legal fight isn’t over. Here’s what business owners need to know:

• Feb. 17, 2025 – A Texas federal court (Smith v. U.S. Department of the Treasury) lifted its nationwide injunction, meaning BOI reporting is once again required. This follows the U.S. Supreme Court’s Jan. 23, 2025, order in Texas Top Cop Shop v. McHenry, which allowed enforcement to resume while the case is under appeal.

What Does This Mean?

• FinCEN has confirmed that businesses are required to file BOI reports once again.

• The new deadline for most reporting companies to file an initial, updated, or corrected BOI report is March 21, 2025.

• Several other lawsuits challenging the CTA are still pending in different federal courts, including:

  • Cmty. Ass’n Inst. v. Yellen (4th Circuit)
  • Firestone v. Yellen (9th Circuit)
  • Nat’l Small Bus. United v. Yellen (11th Circuit)

📅 Key Dates to Watch:

• March 21, 2025 – BOI report filing deadline for most businesses.

• March 25, 2025 – Oral arguments in the Texas Top Cop Shop case before the Fifth Circuit Court of Appeals.

⚖️ Potential Legislative Changes

• Congress is considering (2) new bills that could impact BOI reporting:
• Jan. 15, 2025 – The Repealing Big Brother Overreach Act was reintroduced in the U.S. Senate and House, aiming to repeal the CTA entirely.
• Feb. 10, 2025 – The Protect Small Businesses from Excessive Paperwork Act of 2025 passed the House of Representatives. If enacted, it would extend the BOI reporting deadline to Jan. 1, 2026.

🚨 Take Action:

• If you own or manage a business, make sure you’re compliant with BOI reporting requirements before the March 21 deadline; + 

• Keep an eye on court rulings + potential legislative changes that could impact your obligations.

This situation is evolving—stay tuned for updates.  Due to the continuing uncertainty, please stay informed.  You can find updates directly from FinCEN by visiting their site:  

https://fincen.gov/boi

Need Additional Guidance?

If you’re unsure how this development impacts your business or need help preparing for potential reporting obligations, contact us. Our team is here to help navigate this evolving legal landscape and ensure you’re prepared for any changes.

Current PB Law Clients can schedule a BOI / CTA Q+A Meeting here:

• PB Law Clients BOI CTA Q+A Meeting Booking Link

Interested in becoming a Client? 

• Request a Consult with the Phillips Ballenger Team 

Read More about the CTA:

• PB Law's Guide to the Corporate Transparency Act - CTA and BOI Reporting

• CTA + BOI: Does my company qualify for the "Inactive Entity" Exemption??

- Tiffany Ballenger Floyd, Esq.  | Managing Partner, Phillips Ballenger Estate Attorneys | Licensed in NV + CA

Updated: February 20th, 2025