ACCNJ ALERT

Dear {{CFirstName}}:

Corporate Transparency Act: Filing Requirements Back in Effect After Nationwide Injunction Lifted

To follow up on a previous alert, on February 18, 2025, the U.S. District Court for the Eastern District of Texas granted the Financial Crimes Enforcement Network (FinCen) a stay order on its previously issued preliminary nationwide injunction on the enforcement of the Corporate Transparency Act (CTA). As a result, beneficial ownership information (BOI) reporting requirements are now mandatory for reporting companies.

You may recall, the CTA requires certain entities that meet the definition of “reporting companies” to file BOI reports with FinCEN. To help clarify the new filing deadlines, FinCEN released the following guidance:

1. For most reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025.
2. Reporting companies formed or registered on or after February 18, 2025, must file within 30 days from the date of creation or registration.
3. Reporting companies previously provided with extended deadlines due to disaster relief should follow the later deadlines.

It is important to note that the CTA applies strictly to reporting companies, and a robust list of exempt entities, such as large operating companies, still exists. To qualify under the large operating company exemption, an entity must: (1) employ more than 20 full-time employees in the U.S. (generally working at least 30 service hours per week); (2) have an operating presence at a physical address in the United States; and (3) have filed a federal tax return for the previous year showing more than $5,000,000 of gross receipts.

Regards,

Jon Slater

Associated Construction Contractors of New Jersey
Raritan Center Plaza II
91 Fieldcrest Avenue, Suite A19
Edison, NJ 08837
P: 732.225.2265
jslater@accnj.org

Associated Construction Contractors of New Jersey
Raritan Center Plaza II
91 Fieldcrest Avenue, Suite A19
Edison, NJ 08837
P: 732.225.2265

accnj.org