In the interest of keeping our clients fully aware of their legal and tax obligations, information about the Corporate Transparency Act (CTA) has graced these pages before. At first, the effective date for compliance for pre-2024 companies was December 31, 2024. Newly formed companies were required to comply within 90 days of formation during 2024, dropping to 30 days for 2025 and later. Compliance meant filing a beneficial owners information (BOI) report with the Financial Crimes Enforcement Network (FinCEN), a branch of the Treasury Department. For most companies, filing was fairly straightforward, and the rules potentially applied to 32 million entities.
Compliance Challenges and Shifting CTA Deadlines
Not everyone was a fan of the rules, and enforcement of the CTA was off, then on again, off and on again. In the most recent iteration of on again, the deadline for pre-2024 entities to comply was March 21, 2025. I stopped putting out alerts about the CTA machinations because each time one came out, there was another 180-degree turn. Better to wait until the dust settles. Has it settled?
Current Status and Implications for Domestic Companies
On Sunday, March 2, 2025, the Treasury Department announced that it won’t enforce the CTA against US citizens or domestic reporting companies. Treasury left the door open to enforce the CTA against non-US citizens and foreign reporting companies. This, despite the fact that many of the money laundering situations that have been found involve foreign criminals using domestic entities. While the CTA would appear to be dead in the water for domestic reporting companies, the situation is fluid. Most are taking a wait-and-see approach, but no domestic reporting company should be feeling the pressure to file a BOI report at the moment.
Looking Forward: Awaiting Clear Guidance
Hopefully, Treasury will develop guidance in some form that will be clear and put to rest the frustrating flip-flopping that businesses have tried to navigate over the last year. Stay tuned.
Stay Informed on Corporate Transparency Act Changes
For ongoing updates and insights on regulatory changes that may impact your business, subscribe to our firm insights or contact us for about services tailored to your specific situation.
Commercial real estate trends in 2026 are being shaped by shifting economic conditions, technological innovation, and evolving tenant demands. As the market adjusts to changing interest rates, capital flows, and workplace models, investors, owners, tenants, and developers must understand how these trends are influencing opportunities and risk in the year ahead. Overall Outlook for Commercial […]
One Big Beautiful Bill: New Tip Income Tax Rules Employers & Workers Need to Know
Part 2 – Tips Excluded from Income Certain employees and independent contractors may be eligible to deduct tips from their income for tax years 2025 through 2028 under provisions included in the One Big Beautiful Bill. The deduction is capped at $25,000 per year and begins to phase out at $150,000 of modified adjusted gross […]
One Big Beautiful Bill: New Overtime Tax Rules Employers and Employees Need to Know
Part 1 – Overtime Pay and Income Tax Treatment Overview This Firm Insights post summarizes one provision of the “One Big Beautiful Bill” related to the tax treatment of overtime compensation and related employer wage reporting obligations. Overtime Pay and Employee Tax Treatment The Fair Labor Standards Act (FLSA) generally requires that overtime be paid […]
New York’s FAIR Business Practices Act: What the New Consumer Protection Measure Means for Your Business
In 2025, New York enacted one of the most consequential updates to its consumer protection framework in decades. The Fostering Affordability and Integrity through Reasonable Business Practices Act (FAIR Act) significantly expands the scope and strength of New York’s long-standing consumer protection statute, General Business Law § 349, and alters the compliance landscape for New York […]
How to Reduce Legal Risk as Your New Jersey Business Grows in 2026
For many New Jersey businesses, growth is a primary objective for the New Year. However, it is important to recognize that growth involves both opportunity and risk. For example, business expansion often results in complex contracts, an increased workforce, new regulatory requirements, and heightened exposure to disputes. Without proactive planning, even routine growth can lead […]
Crypto Investor Protection: SEC and CFTC Enforcement Trends
Crypto investor protection continues to evolve, with the SEC and CFTC investing resources and coordinating more closely to uphold regulatory standards. Whether you’re a retail investor, an institutional trader, or part of a crypto startup, understanding enforcement trends is essential for navigating this dynamic and high-stakes regulatory environment. Crypto Is No Longer the Wild West […]
No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.
Sign up to get the latest from our attorneys!
Explore What Matters Most to You.
Consider subscribing to our Firm Insights mailing list by clicking the button below so you can keep up to date with the firm`s latest articles covering various legal topics.
Stay informed and inspired with the latest updates, insights, and events from Scarinci Hollenbeck. Our resource library provides valuable content across a range of categories to keep you connected and ahead of the curve.
Let`s get in touch!
Sign up to get the latest from the Scarinci Hollenbeck, LLC attorneys!
