March 2, 2025:
The U.S. Treasury Department has announced (March 2, 2025) that it will not enforce any penalties or fines associated with the Corporate Transparency Act’s beneficial ownership information reporting rule under the existing regulatory deadlines. Additionally, 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.”
Below are reactions to this news from various organizations.
National Cattlemen’s Beef Association
The National Cattlemen’s Beef Association (NCBA) thanked (March 3, 2025) President Donald Trump and U.S. Treasury Secretary Scott Bessent for suspending enforcement of the Corporate Transparency Act (CTA) and limiting the scope of the law to protect family farms and ranches from excessive regulations.
“Family farmers and ranchers across the country are breathing a sigh of relief thanks to President Trump and Secretary Bessent suspending the Corporate Transparency Act reporting requirements for American citizens,” said NCBA President Buck Wehrbein, a Nebraska cattleman. “We appreciate President Trump’s common-sense approach and continued support for rural America and the hard-working cattle producers who feed our nation.”
For months, the CTA reporting requirements have been subject to litigation, temporary enforcement pauses, and other changes that have created confusion for small business owners across the country. The announcement from the U.S. Department of the Treasury provides some short-term protection from the CTA’s enforcement penalties while the agency works to craft new regulations that protect U.S. citizens from burdensome reporting requirements.
“For over a year, cattle producers have been extremely concerned with the ever-changing direction of the Corporate Transparency Act and the steep punishment associated with non-compliance,” said NCBA Executive Director of Government Affairs Kent Bacus. “Without President Trump’s intervention, millions of small business owners may have been in violation with the law. We greatly appreciate Treasury developing a new rule that provides certainty for small businesses and protects American agriculture.”
NCBA continues to encourage cattle producers to consult with their attorney and/or tax professional about this latest development.
January 27, 2025:
National Cattlemen’s Beef Association Executive Director of Government Affairs Kent Bacus reacted to the U.S. Supreme Court’s decision to lift the injunction that temporarily halted enforcement of the Corporate Transparency Act’s reporting requirements.
“Cattle producers across the country are disappointed in the Supreme Court ruling, which will allow the federal government to blanket family-owned farms and ranches in fresh red tape while subjecting millions of law-abiding small business owners to potential legal jeopardy,” Bacus said. “We urge President Trump and his administration to rescue millions of American small business owners from these burdensome reporting requirements and delay enforcement until a meaningful solution is found.”
The Court placed a previous injunction on hold that had been in place since December. Reuters says enforcing the law is still blocked and companies aren’t required to report the information resulting from a separate order issued on January 7, 2025, by a U.S. District Judge in Texas.
DECEMBER 30, 2024:
National Cattlemen’s Beef Association (NCBA) Executive Director of Government Affairs Kent Bacus issued a statement following the latest court development that has once again put the Corporate Transparency Act reporting requirements temporarily on hold:
“In a new decision, the U.S. Fifth Circuit Court of Appeals reversed a previous ruling they issued before Christmas and has instead decided to uphold the injunction blocking the Corporate Transparency Act from taking effect. This means that cattle producers have another temporary reprieve from filing beneficial ownership information with the U.S. Treasury. These court rulings have gone back and forth and continue to add to confusion. NCBA urges all cattle producers to consult with their attorney and/or tax professional for the latest information.
“On Christmas Eve, NCBA sent a letter to Secretary of the Treasury Janet Yellen urging a delay in enforcing the Corporate Transparency Act. NCBA is also continuing to urge Congress to pass legislation that will permanently protect cattle farmers and ranchers from this burdensome mandate.”
Background
On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction that temporarily halted enforcement of the Corporate Transparency Act. The U.S. government appealed the ruling and on December 23, a panel of the U.S. Court of Appeals for the Fifth Circuit overturned the injunction. After that ruling, the Financial Crimes Enforcement Network (FinCEN) announced that the deadline for beneficial ownership report filing was January 13, 2025. On December 26, the full U.S. Court of Appeals for the Fifth Circuit reversed their previous decision, and the Corporate Transparency Act is once again temporarily on hold. FinCEN has suspended enforcement and will accept voluntary reports.
DECEMBER 24, 2024:
On Monday (Dec. 23, 2024), the 5th U.S. Circuit Court of Appeals lifted a federal district court’s earlier order, which had previously halted the Jan. 1, 2025, deadline for small businesses to file their Beneficial Ownership Information (BOI) with the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) per the Corporate Transparency Act (CTA) passed by Congress and signed by President Biden in 2021.
The Continuing Resolution passed by Congress and signed into law last week, which continues funding the government and extends the 2018 farm bill, did not include amendments to provide any exception to the FinCEN requirement for farmers.
In light of the Fifth Circuit’s decision, FinCEN announced it will delay enforcement of the Corporate Transparency Act until January 13, 2025—just three weeks from now. This delay does not allow enough time for millions of small businesses to comply with the law, and it is deeply concerning that FinCEN will proceed with enforcing this law when it has failed to give adequate notice and instructions to law abiding family business owners.
The CTA requires that the owners and part-owners of an estimated 32.6 million small businesses — including an estimated 230,000 farms — must register personal information with FinCEN, such as a photo ID and home address.
American Farm Bureau Federation says that this appeals court ruling now “puts tens of thousands of farms back on the legal deadline to register their businesses with the federal government. Farmers who operate corporations and limited liability companies are once again required to file Beneficial Ownership Information or face stiff fines or jail time.”
Analysis from AFBF economists shows that of the more than 230,000 farms likely required to file, less than 11% had done so as of October 2024. Read more from AFBF here. Farmers are encouraged to contact an accountant or attorney if they are unsure whether they are required to file their business’s BOI with FinCEN.
National Cattlemen’s Beef Association— “The Corporate Transparency Act requires millions of family farmers and ranchers to file complex paperwork and disclose beneficial ownership information with the federal government under penalty of severe fines and jailtime,” said NCBA Executive Director of Government Affairs Kent Bacus. “FinCEN should do the right thing and provide a realistic delay to the Corporate Transparency Act until Congress has an opportunity to provide a permanent fix that protects family farmers and ranchers.”
The U.S. Chamber of Commerce has a summary CTA information and requirements that is available here.
DECEMBER 5, 2024:
A Texas federal court halted the implementation of the Corporate Transparency Act’s beneficial ownership reporting requirements that included America’s farmers, ranchers, and agribusinesses. The court held the CTA as likely unconstitutional, so it issued a preliminary injunction barring the government from enforcing the Act and its reporting requirements against anyone.
Before the ruling, small businesses that met certain criteria would have had to file reports with the Treasury Department by January 1, 2025, or risk fines and criminal penalties. The preliminary relief will remain in effect until the conclusion of legal proceedings, at which point the court may enter a permanent injunction. In the meantime, the government is expected to appeal the preliminary injunction.
The U.S. Chamber of Commerce says unless and until an appellate court overrules or narrows the injunction, no businesses are obligated to comply with the reporting requirements. Congress enacted the CTA on January 1, 2021.
AUGUST 27, 2024:
R-CALF USA has joined as a plaintiff in a joint lawsuit against the U.S. Department of the Treasury and others, challenging the constitutionality of the Corporate Transparency Act (CTA). The groups are seeking to prohibit enforcement of the CTA and an additional declaration of the CTA’s unconstitutional status in a Utah District Court.
Effective January 1, 2024, the CTA requires all state or tribal registered entities, including those with under 20 employees, such as limited liability companies (LLCs), to report private, sensitive information on “beneficiary owners” to the federal government, which will be stored in a database.
In the suit, the plaintiffs note that the CTA’s reporting obligations mainly apply to small business owners while many large corporations are exempt from reporting. The groups also outlined the harsh penalties for noncompliance, financial and legal burdens on small business owners, the federal overreach into states’ rights and regulations of business ownership and formation, and several constitutional violations.
R-CALF USA CEO Bill Bullard said that his group is seeking an injunction on behalf of its members for protection from what they consider an unconstitutional imposition on private information.
“This law was intended to identify those who already don’t follow the law when it comes to money laundering, terrorism funding, and other illicit financial activities,” said Bullard. “Rather than put money or time into law enforcement or detective work to find these alleged criminals, the government chose instead to place a significant burden on law-abiding small business owners.”
“The CTA is an egregious overuse of federal power that seeks to invade personal and private data of small business owners and their associates across America,” said R-CALF USA Property Rights Committee Chair Shad Sullivan. “Another blow to hard-working Americans who are the backbone of small communities across this nation.”
“An initial victory in what could be a protracted case would be the immediate granting of an injunction to prevent the federal government from enforcing the CTA against R-CALF USA members while the case makes its way through court,” Bullard said.
Cowards