U.S. Treasury Issues New Guidance: Beneficial Ownership Information (BOI) Reporting Requirements Suspended
IMPORTANT UPDATE
What Happened?
The federal government’s position on BOI reporting took a drastic change. On Sunday, March 2, 2025, the U.S. Treasury Department issued a news release (Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting Companies) that said for all entities it would not enforce any penalties or fines under the existing guidance and due dates. In addition, it promised no enforcement against U.S. citizens or domestic reporting companies or their beneficial owners under forthcoming rule changes. The expected rule changes would limit BOI reporting to only foreign reporting companies.
What Does This Mean?
The Treasury Department intends to exempt the majority of business entities from future BOI reporting requirements. Legally, the BOI reporting requirements are still in effect, but as a practical matter, since no fines or penalties will be imposed for non-filing, the BOI program has temporarily ended. It appears that when resumed, only foreign entities will be subject to reporting requirements.
What Should Business Owners Do Now?
Once again, BOI reporting requirements are uncertain. Court cases will continue, and likely new cases will challenge the Treasury’s enforcement position and forthcoming regulations. Until the new regulations are actually issued, we do not know exactly who will be subject to BOI reporting. Until then, entities may choose not to file BOI reports and will not be subject to any fines or penalties.
We will continue to post updates as new developments occur.
For more information on the BOI reporting rules and earlier legal decisions, please refer to our previous article: Federal Reporting Requirement: Beneficial Ownership Reporting Rule (BOI) Filing Requirement Currently Suspended
