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Corporate Transparency Act Effective Again

Client Alert
February 20, 2025

Over the past several months, the federal judiciary has provided numerous rulings on the enforceability of the Corporate Transparency Act (CTA), which became effective January 1, 2024. For a more detailed overview on the CTA, click here.

On January 24th, we alerted business owners that enforcement of the CTA was barred nationwide pursuant to federal litigation in Texas (Smith v. U.S. Department of the Treasury, Case No. 6:24-cv-336-JDK). However, on February 18th, the Court in Smith lifted its previous stay which prevented enforcement of the CTA.

Due to this updated ruling, the CTA’s reporting requirements are back in effect nationwide. Non-exempt entities now have until March 21, 2025 to submit required reporting. 

Entities that have not completed reporting should re-engage compliance efforts immediately to meet this updated deadline. The civil penalty for failing to file reporting required under the CTA is $591 per day, up to a total of $10,000. Note also that criminal penalties are authorized for any person who willfully (i) provides or attempts to provide false/fraudulent information, or (ii) fails to report and/or update a report previously made.

For guidance on complying with these updated requirements, business owners should reach out to their BMD legal advisors or contact BMD Member Blake Gerney at brgerney@bmdllc.com.

Corporate Transparency ActBusiness & Corporate LawBlake R. GerneyMichael SneeringerNathan AltstadtJacob R. Davis
Client Alert

Corporate Transparency Act Overhauled: U.S. Entities No Longer Required to Report

March 24, 2025The Department of Treasury has issued an interim final rule significantly altering the Corporate Transparency Act (CTA). As of March 21, 2025, all U.S.-created entities and their beneficial owners are exempt from reporting requirements. Only non-U.S. entities registered to do business in the U.S. must still report, but they are not required to disclose U.S. citizen owners. Business owners should stay informed on these changes and consult legal counsel for compliance guidance.Client Alert

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Ohio Appellate Court Rules in Favor of Gender-Affirming Care

March 19, 2025On March 18, 2025, the 10th District Court of Appeals in Franklin County ruled that Ohio’s House Bill (HB) 68, which restricts puberty blockers and hormone therapy for minors seeking gender-affirming care, violates the Health Care Freedom Amendment and is therefore unenforceable. The court found that the law unlawfully interferes with parental rights and medical decision-making. The case, Moe v. Yost, has been remanded, and Ohio Attorney General Dave Yost intends to appeal.Client Alert

HHS Revokes Public Comment Requirement on Certain Policy Changes

March 5, 2025The U.S. Department of Health and Human Services (HHS) has revoked the Richardson Waiver, eliminating the requirement for public notice and comment on certain policy changes. This decision allows HHS to implement new policies more quickly, potentially affecting healthcare funding rules like Medicaid work requirements. While it speeds up policymaking, it also reduces opportunities for stakeholder input, raising concerns over transparency and unintended consequences for healthcare providers, states, and patients.Client Alert

Don't Get Caught Dazed and Confused: Another Florida Court Weighs in on Employer Obligations to Accommodate Medical Marijuana Use

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