Update: Treasury Suspends the Corporate Transparency Act

Updated 3-3-2025: The Treasury Department has reversed course on enforcing the Corporate Transparency Act after outreach from 120 small business trade associations. No domestically owned business will be required to file before the March 21, 2025 deadline. This reversal comes less than a month after the department urged DOJ to appeal an injunction already pausing enforcement.

The Treasury Department release on the changes said:

The Treasury Department is announcing today that, with respect to the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either. The Treasury Department will further be issuing a proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only. Treasury takes this step in the interest of supporting hard-working American taxpayers and small businesses and ensuring that the rule is appropriately tailored to advance the public interest.

This should end the rollercoaster of changes to CTA that have affected whether businesses are required to file.

Updated 2-27-2025: Following an appeal by the Department of Justice and the Supreme Court reversing an injunction against the Corporate Transparency Act, a Texas court has lifted its second injunction against the CTA. In light of the sudden change, FinCEN (Finance Crimes Enforcement Network) provided 30 days for businesses to file, setting the deadline for March 21, 2025. Interestingly, this is one of the few cases in which the Trump Administration’s DOJ did not seek to delay action and instead filed an appeal on February 5, the day Attorney General Pam Bondi was confirmed. This was a surprise to the business community who believed the Administration would side with them against the law. Both Vice President Vance and SBA Secretary McMahon voice opposition to the CTA.

HARDI joined over 120 trade associations in asking the Treasury Department to delay enforcement until 2026 to allow the court cases to play out.

Original: Last week, the U.S. Supreme Court reversed an injunction stemming from Texas Top Cop Shop Inc. v. McHenry, one of two major court cases challenging the Corporate Transparency Act. While the Supreme Court undid this injunction, a second injunction remains in place and stems from the Smith v. U.S. Dept. of Treasury case from a different federal court judge. This means a nationwide injunction is still in effect, and no companies are required to submit beneficial ownership information to FinCEN.

Due to the uncertainty caused by the back-and-forth between courts, HARDI supports the Repealing Big Brother Overreach Act introduced by Senator Tommy Tuberville (R-AL) and Representative Warren Davidson (R-OH). HARDI signed a coalition letter supporting this legislation and urging Congress to provide certainty to businesses nationwide.

Read more HARDI articles: Nationwide Injunction on Corporate Transparency Act Enforcement Restored, But Legal and Legislative Battles Loom

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