We’re not sure whether to pop champagne or schedule a nap. But after nearly a year of roller-coaster updates, legal reversals, deadline extensions, and agency backpedaling, we are thrilled to say: BOI reporting is officially behind us. (For nearly all of you, at least.)
Here’s how it all ended — and why you can finally exhale.
As of March 2025, an interim final rule from Treasury revised the Corporate Transparency Act (CTA) to exclude domestic companies from the Beneficial Ownership Information (BOI) filing requirements.
That means more than 99% of small businesses, LLCs, partnerships, and S Corps are now exempt, ending the compliance panic that had gripped business owners and advisors nationwide.
We’ve written over a dozen updates, logged a full 40 hours (if not more) untangling legal knots, and lost track of how many times BOI reporting was on, off, and back on again — so yes, we’re more than ready to put this saga to rest.
Here’s a look at the legal chaos that’s unfolded just since December.
🟥 Dec 3, 2024 — A Texas federal court halts CTA enforcement nationwide (Texas Top Cop Shop case). BOI reporting is off.
🟨 Dec 5–17, 2024 — FinCEN confirms: no reports are required while the injunction stands. The government scrambles with motions and appeals, all denied.
🟩 🟥 Dec 23–26, 2024 — The Fifth Circuit temporarily revives CTA enforcement. FinCEN pushes the deadline to Jan 13. Then, plot twist, the injunction is back in place. BOI reporting is off again.
🟨 Dec 27–31, 2024 — FinCEN confirms reports are now voluntary. The government petitions the Supreme Court to step in.
🟥 Jan 7, 2025 — Another court, another case (Smith v. Treasury). A second nationwide CTA injunction drops. BOI reporting still on ice.
🟩 🟥 Jan 23–24, 2025 — SCOTUS lifts the Top Cop Shop injunction. FinCEN says, still voluntary for now, since Smith is still in play.
🟨 Feb 5, 2025 — Government appeals Smith and requests to lift that injunction, too.
🟨 Feb 10–12, 2025 — The House passes a bill (H.R. 736) to delay CTA deadlines until 2026. A similar bill is introduced in the Senate.
🟩 Feb 14, 2025 — A Maine federal judge upholds the CTA’s constitutionality (Boyle v. Bessent). Momentum builds for CTA enforcement.
🟩 Feb 17, 2025 — The court lifts the Smith injunction (pending appeal). CTA enforcement is back.
🟩 Feb 18, 2025 — FinCEN announces: BOI reporting is officially mandatory, with a new deadline of March 21, 2025, plus proposed rule changes to reduce compliance burdens.
💥 March 2025 — Treasury drops a bombshell: a new interim final rule will exempt U.S. companies from BOI reporting altogether. Enforcement drops. Deadlines vanish. The saga ends.
Unless your business is a foreign reporting company (formed outside the U.S. but registered to do business here), you don’t need to file anything with FinCEN.
If that’s not you, congratulations, you’re done. No action needed.
FinCEN is still accepting public comment through May 2025, but for nearly all of our clients, the CTA chapter is closed for now.
This was one of the most confusing regulatory shifts we’ve seen in years, but you hung in there. And we made it through together.
While we don’t prepare BOI reports ourselves, we stayed on top of every twist so you didn’t have to. For now, we’re setting the BOI binder aside — still within arm’s reach — in case Treasury decides to revisit it. (Let’s hope not.)
Thanks for trusting MGA to be your source for clarity in the clutter. We’ll keep doing what we do best: making the complex simple.
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