We recently informed you that the Beneficial Ownership Information (“BOI”) reporting requirements under the Corporate Transparency Act (“CTA”) were reinstated. However, on March 2 the U.S. Department of the Treasury announced that it will not take any enforcement action, such as issuing penalties or fines, for failure to comply with the BOI reporting requirements of the CTA. While the deadline to file, correct or update a BOI report remains March 21 for most small businesses, businesses will not be penalized for failing to file a report.
The CTA is pending further litigation and legislation to potentially repeal or revise the law. Further, the U.S. Department of the Treasury has announced that it intends to propose a rule to narrow the scope of the CTA to foreign reporting companies.
BOI reports are still being accepted if you would prefer to file. The reports can be filed with the U.S. Treasury Financial Crimes and Enforcement Network (“FinCEN”) at https://www.fincen.gov/boi, or we can connect you with a third-party service provider to provide further assistance.
It seems that more changes are coming. We will keep you updated when information becomes available.