Updated: February 26, 2025
The back and forth of the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirement has swung back to mandatory compliance. A Financial Crimes Enforcement Network (FinCEN) notice (FIN-2025-CTA1 FinCEN-BOI-Notice-Deadline-Extension-508FINAL.pdf) on February 18, 2025, reinstated the BOI reporting requirements under the CTA. This notice follows the February 18, 2025, decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of Treasury, et al., 2025 U.S. Dist. LEXIS 2321, to stay its January 7, 2025, order until the appeal is completed.
The reinstatement of the BOI reporting requirement comes with a reporting deadline of March 21, 2025. By that date, all reporting companies must file their initial, updated, and/or corrected BOI reports. Of note, reporting companies that were previously given a reporting deadline later than March 21, 2025, must file their initial BOI report by the later deadline.
As has been previously seen, pending court case rulings or proposed legislation could impact the mandatory reporting of BOI prior to the deadline of March 21, 2025; but the likelihood of that is unknown. Failure to comply with the reporting requirements can result in civil penalties of up to $500 for each day that the violation continues, or criminal penalties including imprisonment for up to two years and/or a fine of up to $10,000. Therefore, the recommendation is to file the BOI report by March 21, 2025, to ensure compliance with the CTA.
If you would like assistance in filing your company’s BOI report, please contact your attorney or one of our Wisconsin Business Law Attorneys. Note, we will need the following information to file the BOI report on your behalf:
- a copy of each owner’s Driver’s License or other acceptable ID (State/local/tribe-issued ID, U.S. passport, or foreign passport)
- a listing of the beneficial owners of the company
- the EIN for the company or SSN being used for the company
- the principal office address
Schloemer Law Firm, S.C. has been in the business of helping Wisconsin businesses with all of their legal needs for over 95 years. We frequently assist Wisconsin businesses throughout the state, and specifically in the areas of Washington County, Dodge County, Ozaukee County, Fond du lac County, West Bend, Hartford, Slinger, Fond du Lac, Sheboygan, Menomonee Falls, and surrounding areas.
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Disclaimer: The information contained in this post is for general informational purposes only and is not legal advice. Due to the rapidly changing nature of law, Schloemer Law Firm makes no warranty or guarantee concerning the accuracy or completeness of this content. You should consult with an attorney to review the current status of the law and how it applies to your unique circumstances before deciding to take—or refrain from taking—any action. If you need legal guidance, please contact us at 262-334-3471 or [email protected].