February 26th, 2025 – New York, United States  

CTA/BOI Reporting Moves Forward With Delayed Deadlines

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Developments continue with the U.S. Corporate Transparency Act and its Beneficial Ownership Information reporting requirement even as the reporting deadline is extended.

A federal judge in Maine has ruled that the U.S. Corporate Transparency Act is justified under the commerce clause of the U.S. Constitution. A federal judge in Texas has also lifted a previous injunction concerning the CTA.

U.S. District Judge Stacey D. Neumann in Maine granted a motion for summary judgment from the U.S.  government. She denied a similar bid from William Boyle, a majority owner of companies in the state who sued last year in March seeking a judgment that the CTA is unconstitutional. Other taxpayers have filed similar suits, with varying success.

In her ruling, Judge Neumann said the U.S. Congress was correct in finding that the so-called beneficial ownership information (BOI) called for in the CTA is necessary for protecting interstate and foreign commerce, and that lawmakers “asserted a rational basis for concluding the existence of corporate entities has a substantial effect on interstate commerce.”

U.S. District Judge Jeremy Kernodle in Tyler, Texas, has also put on hold an order he previously issued halting the CTA’s enforcement after President Trump’s said it would reevaluate regulations implementing the law “to alleviate the burden on low-risk entities.”

All domestic and foreign entities formed or registered to do business in the U.S. must file the BOI report unless they meet conditions of exception. Companies must report contact information on all individuals who own or control at least 25% of the ownership interests of the company. The initial reporting deadline for many companies was Jan. 1. Failure to report can carry fines of some $600 per day to imprisonment. 

Deadline delayed

But acknowledging “that reporting companies may need additional time to comply with their BOI reporting obligations” and citing “a commitment to reducing regulatory burden on businesses,” the Financial Crimes Enforcement Network of the U.S. Treasury is generally extending the deadline for most companies to report BOI, to March 21.

The agency added it will provide an update before then of any further modification of this deadline. Any company that has been given a reporting deadline later than March can continue to file by the later date. 

Further delays are possible. On Feb. 10, the U.S. House of Representatives passed the Protect Small Business from Excessive Paperwork Act, a bipartisan-supported measure that proposes postponing the BOI reporting deadline for most companies to Jan. 1, 2026. The bill now heads a U.S. Senate committee.

Two Republican congressmen, Sen. Tommy Tuberville of Alabama and Representative Warren Davidson of Ohio, have also reintroduced the Repealing Big Brother Overreach Act, a bill to eliminate the Corporate Transparency Act. This bill does not have bipartisan support.

We’ll keep you updated on the rapidly changing situation with BOI reporting.

Your tax specialist needs to stay on top of this and many other issues of wealth, foreign income and tax enforcement. If we can help, please let us know.

About the Author 

Alicea Castellanos is the CEO and Founder of Global Taxes LLC. Alicea provides personalized U.S. tax advisory and compliance services to high-net-worth families and their advisors.

Alicea has more than 20 years of experience. Prior to forming Global Taxes, Alicea founded and oversaw operations at a boutique tax firm, worked at a prestigious global law firm and CPA firm.

Alicea specializes in U.S. tax planning and compliance for non-U.S. families with global wealth and asset protection structures which include non-U.S. trusts, estates and foundations that have a U.S. connection.

Alicea also specializes in foreign investment in U.S. real estate property, and other U.S. assets, pre-immigration tax planning, U.S. expatriation matters, U.S. persons in receipt of foreign gifts and inheritances, foreign accounts and assets compliance, offshore voluntary disclosures/tax amnesties, FATCA registration, and foreign companies wanting to do business in the U.S.

Alicea is fluent in Spanish and has a working knowledge of Portuguese.

Alicea is an active member of the Society of Trusts & Estates Practitioners (STEP), the New York State Society of Certified Public Accountants (NYSSCPAs), the American Institute of Certified Public Accountants (AICPA), the International Fiscal Association (IFA), a member of Clarkson Hyde Global, a world-wide association of accountants, auditors, tax specialists and business advisors and the Global Referral Network (GRN).

Distinctly, in 2020, Alicea was awarded with a prestigious NYSSCPA Forty Under 40 Award. She was selected as someone that has notable skills and is visibly making a difference in the accounting profession.

In 2021 and 2022, Alicea was the Gold and Silver Winner, respectively, of Citywealth’s Powerwomen Awards in the category USA – Woman of the Year – Business Growth (Boutique). In 2023, she continued her winning streak by receiving the Gold award for Company of the Year Female Leadership (Boutique) and the Silver award for Accountancy Firm of the Year at the Magic Circle Awards. Furthermore, Alicea has consistently secured her position in the Global Elite Directory for four consecutive years, being recognized as a Private Client Global Elite Advisor and is currently listed for 2024 as a Non-Legal Adviser. This exclusive directory annually highlights the world’s elite lawyers and outstanding wealth advisors serving ultra-high net-worth clients.

Please note: This content is intended for informational purposes only and is not a replacement for professional accounting or tax preparatory services. Consult your own accounting, tax, and legal professionals for advice related to your individual situation. Any copy or reproduction of our presentation is expressly prohibited. Any names or situations have been made up for illustrative purposes — any similarities found in real life are purely coincidental.