Throughout the saga of the Corporate Transparency Act (CTA), I have often been reminded of the fable of The Boy Who Cried Wolf - that the repeated messaging to file or not file, followed by false alarms due to injunctions and extensions, would lead to nobody listening or taking action. However, I may have picked the wrong story for inspiration. As with the Wicked Witch of the West, perhaps we can now declare, “Ding, Dong, the CTA is dead.”
While Wicked did not fare well at the Oscars last night even with a rousing performance by the Elphaba (the aforementioned Witch) and Glinda, it is perhaps coincidental that on the same night Treasury issued a press release that functionally dropped Dorothy’s house onto the CTA itself…
In the spirit of that message, I cannot promise you that this will be the last article on the CTA because unless or until 31 U.S.C. 5336 is repealed or amended by Congress, it is still a federal law. But here is Treasury’s March 2, 2025 press release:
The Treasury Department is announcing today that, with respect to the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either. The Treasury Department will further be issuing a proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only. Treasury takes this step in the interest of supporting hard-working American taxpayers and small businesses and ensuring that the rule is appropriately tailored to advance the public interest.
“This is a victory for common sense,” said U.S. Secretary of the Treasury Scott Bessent. “Today’s action is part of President Trump’s bold agenda to unleash American prosperity by reining in burdensome regulations, in particular for small businesses that are the backbone of the American economy.”
For now, it appears that no filing is required under the current rules. And, pending new rules, only foreign reporting companies will be subject to the obligations of the CTA moving forward.