NYSDA Publications

Federal Corporate Transparency Act Back in Effect

Feb 20, 2025
The federal Corporate Transparency Act is back in effect with all nationwide injunctions against its enforcement canceled.  March 21, 2025, is the new compliance deadline for entities to report their beneficial ownership information (many dental practices have already done so).  This law has had a bizarre history.  In Texas Top Cop Shop, Inc. v. Garland, a nationwide injunction had been issued by a Texas federal court that was subsequently reversed by the United States Supreme Court.  However, before that happened, a second Texas federal court in Smith v. U.S. Department of the Treasury, issued another nationwide injunction that remained in effect because the Supreme Court decision did not address or have any effect on the second injunction.  Now, the second Texas federal court has canceled its injunction, which effectively eliminates all the nationwide injunctions on the Corporate Transparency Act.  The United States Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced March 21, 2025, as the new deadline for reporting companies to file an initial, updated, and/or corrected beneficial ownership information report pursuant to the Corporate Transparency Act.  Any reporting companies that had previously been given a reporting deadline later than March 21, 2025, may file their beneficial ownership information by the later deadline (this is not a common situation and mainly involves disaster relief scenarios).  FinCEN also announced that it will use the time between now and the new deadline to assess other implementation changes it may want to adopt, although FinCEN gave no details about what it might be considering.