Picture this: the Corporate Transparency Act (CTA) is like a pesky mole popping up and ducking down in a never-ending game of whack-a-mole. Just when you think you’ve got it pinned, it vanishes—only to resurface somewhere else. We’re here to keep you swinging the mallet with the latest updates. As of February 19, 2025, here’s where the mole’s at:
The Mole Pops Up Again (February 25, 2025 Update)
After a courtroom brawl in Texas (Smith, et al. v. U.S. Department of the Treasury), the U.S. District Court for the Eastern District told the Financial Crimes Enforcement Network (FinCEN) to stop hiding. The beneficial ownership information (BOI) rules are back in play! If your company’s a “reporting company,” it’s time to name names. But don’t sweat it too hard—FinCEN’s giving you a breather with a new deadline: March 21, 2025. They know this game’s been a wild one, and you might need a sec to find your mallet.
Whack These Facts
- BOI’s Back in the Hole: Reporting’s mandatory again for most companies under the CTA.
- March 21, 2025—Mark It: That’s your swing-by date, unless you’ve got a later deadline (like disaster relief folks—stick to your original plan).
- Some Moles Stay Buried: Companies tied to National Small Business United v. Yellen get a timeout for now.
- More Mole Mischief?: FinCEN might shuffle deadlines again, especially for high-stakes players. They’re also plotting to make life easier for small businesses who aren’t exactly mole-ving mountains of risk.
- Swing Online: File your BOI report through FinCEN’s E-Filing system—easy peasy.
Your Whack-a-Mole Moves
- Grab Your Mallet: Haven’t filed? Start prepping now for March 21.
- Call in Backup: Check with a lawyer to make sure you’re swinging at the right mole.
- Keep Watching the Holes: This game’s not over, so stay ready for FinCEN’s next pop-up announcement.
January 23, 2025: The Mole Took a Nap
A month back, the CTA mole was playing hard to get. The Supreme Court whacked one injunction (Texas Top Cop Shop, Inc. v. McHenry), but another (Smith v. U.S. Department of Treasury) kept it underground. Reporting? Totally optional. Some companies swung anyway, filing voluntarily, while others just watched the holes. Congress even tossed around ideas of shutting down the game entirely with bills like H.R. 425 and S. 100. The Fifth Circuit? They were gearing up for a big swing on March 25, 2025. It was a “get ready, but don’t whack yet” vibe.
December 26, 2024: Mole Madness Begins
Back in December, the mole popped up fast. The Fifth Circuit smashed an injunction (Texas Top Cop Shop, Inc. v. Garland), and BOI rules were suddenly live. Deadlines got a quick nudge:
- Pre-2024 companies? Whack by January 13, 2025.
- Late 2024 newbies? Same, or maybe an extra 21 days if you were super fresh.
- 2025 startups? 30 days from your “hello, world” notice.
Everyone scrambled—until the mole ducked again.
The Bottom Line
This CTA whack-a-mole game’s got more ups and downs than an arcade scoreboard. Right now, aim for March 21, 2025, unless you’re exempt or the mole moves again (and honestly, it probably will). Need a hand? Our Corporate and Tax attorneys are pros at this game—they’ll keep you swinging straight.
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