Client Alert: Corporate Transparency Act – CTA on Ice Once Again

By Zachary M. Chupak and Julie K. O’Neill • March 3, 2025

Yesterday, March 2, 2025, the Treasury Department announced that it would not enforce penalties or fines relating to the Corporate Transparency Act against U.S. citizens or domestic reporting companies or their beneficial owners. Instead, the Treasury Department will propose rulemaking that will “narrow the scope of the rule to foreign reporting companies only.” The Treasury Department has not yet defined “foreign reporting companies.”

Employers and companies with questions about how to comply with the CTA should consult their Bowditch attorney. We will assume you are handling these matters on your own unless you request assistance from your Bowditch attorney in writing.

Categorized: Client Alerts, Publications

Tagged In: business owners, FinCen, Beneficial Ownership Information, foreign reporting companies

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Julie K. O’Neill

Julie O’Neill focuses her practice on business, corporate and securities law, and counseling individuals and entities at all stages of the corporate life cycle on a wide variety of sophisticated transactions in the U.S., Canada, and abroad. Julie regularly handles:

Entity selection and formation
Private placements including angel and venture capital equity financings
Limited liability company operating agreements and shareholders’ agreements
Mergers and acquisitions
Recapitalizations
Private equity fund formation
Secured transactions
Employment issues and partnership disputes
Licensing arrangements and general contract matters
Trademark and copyright registrations

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Zachary M. Chupak

Zachary Chupak is an Associate in the Estate, Financial & Tax Planning Practice Area. He assists high-net worth individuals and families in need of asset protection, business succession planning and gift and estate tax strategies. Multi-generational and blended families seek Zach’s assistance with estate planning, estate administration, probate and tax litigation, and family office needs. 

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