Article highlights:
• Treasury Dept. will no longer enforce CTA reporting requirements against U.S. citizens and domestic companies
• Future rule changes expected to limit reporting requirements to foreign entities
• March 21, 2025, filing deadline no longer relevant for U.S. businesses

The Corporate Transparency Act (CTA) has taken yet another dramatic turn. As previously reported, the final nationwide injunction against enforcement of the CTA was lifted on February 17th. Days later, FinCEN announced another 30-day extension of the filing due date, making the new deadline March 21, 2025. However, on March 2, 2025, the Treasury Department announced it would suspend enforcement of the CTA’s beneficial ownership information (BOI) reporting requirements for U.S. citizens and domestic reporting companies, even if those companies failed to meet the previously extended March 21st filing deadline. The agency said that it intends to issue new rulemaking proposals to focus the CTA’s enforcement solely on “foreign reporting companies.” It remains to be seen whether enforcement would include foreign individuals/entities holding ownership interests in domestic reporting companies — as presumably intended by the original law.

What does this mean?
Because FinCEN will not enforce the CTA reporting rules against domestic businesses, the March 21 deadline for BOI filings is effectively no longer relevant for most entities. The Treasury Department has not yet provided a timeline for issuing its proposed rule changes. However, even though the Treasury has decided not to enforce the CTA right now, the underlying statute remains in effect — meaning Congress will still need to take some action to repeal or modify the existing law. How and when that might happen remains to be seen.

We will continue to monitor and provide updates as new information becomes available. In the meantime, for those who still have questions about their reporting obligations, stay up to date by monitoring the Chuhak Newsroom regularly or contact a member of our CTA team for the latest guidance.