Legal Background and Timeline:
- On January 7, 2025, the U.S. District Court for the Eastern District of Texas issued an order staying FinCEN’s regulations implementing BOI reporting requirements, which temporarily halted the enforcement of the Corporate Transparency Act (CTA).
- For the lawyers keeping track on their score cards at home, this order was in addition to / separate and apart from a December 3, 2024 preliminary junction issued in the Texas Top Cop Shop, Inc. v. Garland case and addressed by the U.S. Supreme Court on January 23, 2025.
- On February 5, 2025, the U.S. Department of Justice, on behalf of the Treasury, appealed the decision and requested a stay of the Order.
- On February, 18, 2025, the U.S. District Court for the Eastern District of Texas granted the government’s motion to stay, effectively reinstating BOI reporting requirements while the appeal is pending.
What Does this Mean For Most Small Businesses / Reporting Companies?
Non-exempt reporting companies must now submit new or updated BOI reports in compliance with the CTA.
Recognizing that companies may need additional time to comply, FinCEN has extended several deadlines per a public statement:
- For most reporting companies, the new deadline to file initial, updated, or corrected BOI reports is now March 21, 2025.
- Entities formed on or after February 18, 2025 remain subject to the 30-day filing rule. For example, an entity formed on February 25, 2025 must submit its BOI report by March 27, 2025 (30 days from its formation date).
- Reporting companies that have previously been granted a disaster relief or other deadline extension that is later than March 21, 2025 still have until that later deadline to file.
Roberts Law, PLLC assists businesses with Corporate Transparency Act compliance. We assist reporting companies with filing their required BOI reports and updates and may serve as a company applicant for new entities. To inquire about these services, please email Josh Roberts at josh@joshrobertslaw.com.
Author: Josh Roberts
Email: josh@joshrobertslaw.com
Josh Roberts is a business and litigation attorney at Roberts Law, PLLC with over a decade of BigLaw and in-house technology experience helping businesses and business owners navigate contracts, privacy concerns, negotiations, and dispute resolutions.
Disclaimer: The information in this blog post (“post”) is provided for general informational purposes only and may not reflect the current law in your jurisdiction or the jurisdiction applicable to your issue/matter. No information contained in this post should be construed as legal advice from Roberts Law, PLLC or the individual author, nor is it intended to be a substitute for legal counsel on any subject matter. No reader of this post should act or refrain from acting on the basis of any information included in, or accessible through, this post without seeking the appropriate legal or other professional advice on the particular facts and circumstances at issue from a lawyer licensed in the recipient’s state, country or other appropriate licensing jurisdiction.
