On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed the nationwide injunction it previously issued that prohibited the federal government from enforcing the Corporate Transparency Act on a nationwide basis. The reversal was based on a January 23, 2025 Supreme Court ruling.
What this means for AAO members: Filing requirements under the CTA are back in effect. Most businesses are now required to file beneficial ownership information reports by March 21, 2025. (Some businesses may have later deadlines due to disaster relief extensions.) The Corporate Transparency Act requires qualifying businesses to file ownership reports to the U.S. Treasury’s Financial Crimes Enforcement Network for the purpose of mitigating money-laundering operations.
According to an ADA News report, “Dental practices must file under the Corporate Transparency Act if they employ fewer than 20 people or if they generate less than $5 million (gross receipts) in revenue annually. Failure to file a report can result in civil and criminal penalties.”
Of note, the U.S. House of Representatives voted to advance the Protect Small Businesses from Excessive Paperwork Act of 2025. If passed into law, the bill would delay the Corporate Transparency Act’s filing deadline to Jan. 1, 2026, for businesses created prior to 2024. The bill will now be considered by the Senate.
In addition, a notice posted by the Financial Crimes Enforcement Network stated: “Notable in keeping with Treasury’s commitment to reducing regulatory burden on businesses, during this 30-day period FinCEN will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN also intends to initiate a process this year to revise the [beneficial ownership information] reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.”
We continue to monitor legal developments closely and will keep our members informed of any changes that may affect their obligations under the CTA.
The timing of possible changes between now and March 21 being uncertain, AAO members who did not complete CTA filing in 2024 may wish to do so to avoid being forced to file at the last minute. Registration can be completed at the link below. Click “Get Started” under the heading “Beneficial Ownership Information (BOI) Reporting.”
BOI E-Filing System
