The Corporate Transparency Act (CTA) is now active again, with a filing deadline set for March 21, 2025. The District Court in Smith v. U.S. Department of the Treasury lifted the last nationwide injunction that had paused the enforcement of the Corporate Transparency Act. As a result, the CTA is now fully enforceable again.
Following the legal victory with Smith, FinCEN has established March 21, 2025, as the new filing deadline for the CTA. There are specific enforcement deadlines and rules for certain companies benefiting from disaster relief or other forms of legal protection.
Although the Smith injunction has been lifted, the final outcome of the CTA is still uncertain. FinCEN’s website update suggests that additional regulatory adjustments may be on the horizon. Specifically, FinCEN noted:
- During the grace period (ending March 21), it will “will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks;” and
- FinCEN “intends to initiate a process this year to revise the [CTA] reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.”
Simultaneously, legislation currently in Congress could either delay or completely repeal the CTA. In the meantime, all reporting companies must comply with the current CTA rules and prepare for the March 21 filing deadline.
If you have any questions about the CTA, please feel free to contact your trusted Rosenberg & Estis, P.C. attorney or William R. Byers, Member of the firm’s Transactional Department, who authored the above on the CTA. Join us on March 11, 2025 for our not-to-be-missed Corporate Transparency Act (CTA) webinar. If you are interested in signing up for our webinar, please reach out to us for more details.