Since the enactment of the Corporate Transparency Act (CTA), business owners have been watching the back-and-forth developments on beneficial ownership information (BOI) reporting like a legal soap opera.
ON: The Initial Rollout
Initially, the CTA required business owners to report details on anyone owning 25% or more of a company or exerting substantial control over it. The information included:
- Full legal name
- Date of birth
- Residential address
- Identification number (driver’s license or passport)
- Company formation details
OFF: Legal Pushback
Businesses quickly pushed back, and several courts issued injunctions, temporarily halting the BOI reporting requirements.
ON AGAIN? Unclear for a While
Some of those injunctions were later overturned or limited to the parties involved. For everyone else, the rules were back on—complete with threats of hefty daily fines for noncompliance. As a result, most businesses scrambled to comply. Still, many held out hope that a new administration might hit the brakes.
OFF: Trump Administration Pulls the Plug
Turns out, that hope wasn’t misplaced. After President Trump’s return to office, the Treasury Department officially announced an indefinite suspension of BOI reporting enforcement for U.S. citizens and domestic companies.
What’s Next?
The Treasury has stated that the BOI rules will be revised to apply only to foreign companies operating in the U.S. President Trump hailed the move as “a victory for common sense,” calling the original rule “outrageous and invasive.”
What This Means for U.S. Businesses
✅ The good news:
Small businesses can breathe a sigh of relief. Many struggled with the FinCEN reporting system, and the looming threat of fines created a stressful environment. For now, BOI reporting is off the table for U.S.-based entities.
⚠️ The downside:
The original intent of BOI reporting—to promote transparency and fight financial crimes—is hard to argue with. While the current suspension shifts that effort, debate continues over whether this rule was ever the right tool for the job. Its absence may not have the dramatic impact some feared.
After all the twists and turns, we can now confidently say that BOI reporting under the CTA is not being enforced against U.S. citizens or domestic companies.
For foreign companies, enforcement still applies, and FinCEN has promised more guidance soon. Stay up to date on their website.
