Update on CTA & BOI Reporting February 20, 2025

New Jersey Society of Enrolled Agents Update on Corporate Transparency Act and Beneficial Ownership Information Reporting Requirements – February 20, 2025

We wish to inform you of recent developments concerning the Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) reporting requirements, which are pertinent to many of our clients and stakeholders.

Reinstatement of BOI Reporting Requirements

On February 17, 2025, a federal judge in Texas lifted a previous injunction that had halted the enforcement of the CTA's BOI reporting obligations. This decision follows a Supreme Court ruling that favored the Treasury Department, allowing the enforcement of the CTA to proceed. As a result, companies are once again required to comply with BOI reporting mandates.

The Wall Street Journal

Extended Filing Deadline

In response to the reinstatement, the Financial Crimes Enforcement Network (FinCEN) has extended the filing deadline for BOI reports to March 21, 2025. This extension aims to provide businesses with additional time to gather and submit the necessary information. FinCEN has indicated that it will provide updates before March 21 regarding any further modifications to the deadline.

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Compliance Recommendations

Given these developments, we recommend the following actions:

• Review Applicability: Determine whether your clients' entities are subject to BOI reporting under the CTA. Generally, corporations, limited liability companies, and other similar entities are required to report.
• Prepare for Filing: Advise affected clients to compile the necessary beneficial ownership information promptly to meet the March 21 deadline.
• Stay Informed: Monitor communications from FinCEN for any updates or changes to the reporting requirements or deadlines.

For detailed information on the reporting process and to submit BOI reports, please visit FinCEN's official website at FinCEN.gov/boi. See FinCEN Notice, FIN-2025-CTA1, 2/18/2025.

If you have any questions please feel free to reach out to the NJSEA Government Relations Committee:  [email protected]