Jack Najarian

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a significant interim final rule that substantially narrows reporting obligations under the Corporate Transparency Act (CTA). Effective as of March 21, 2025, U.S. companies and U.S. persons are exempt from reporting beneficial ownership information (BOI) to FinCEN.

Corporate Transparency Act Reporting Obligations Reinstated, With March 21 Deadline and Possible Further Changes A recent court ruling has once again reinstated the Corporate Transparency Act (CTA) beneficial ownership information (BOI) reporting requirements. On February 17, 2025, the U.S. District Court for the Eastern District of Texas in Smith v. United States Department of the Treasury lifted the injunction that had been blocking enforcement of the CTA.

The Employer Reporting Improvement Act (the “Act”) has filled a glaring hole in the realm of Affordable Care Act (“ACA”) compliance.[1] In its previous form, there was no discernable statute of limitations for the lookback period in which the Internal Revenue Service (“IRS”) could audit an employer’s treatment of “employer shared responsibility payments.” This left employers susceptible to surprise assessments for years following an incorrect disclosure.