Corporate Transparency Act (CTA) Update: March 2025

The U.S. Treasury Department issued a press release on Sunday, March 2nd announcing the end of enforcement of the Corporate Transparency Act (“CTA”) against domestic entities. On Friday March 21st, FinCEN posted a regulatory pronouncement that almost entirely eliminated the CTA requirements for the time being.

The CTA will now only apply to foreign entities that have registered to do business or co-exist in the United States, and such registration will only require disclosure of information on foreign owners and foreigners who are in control of such entities. The filing deadline for foreign entities has been delayed until April 25th.

So, unless Congress takes additional action, the CTA is dead for domestic entities and more than 99% of those initially targeted by Congress’ intent. Again, it will only apply to foreign entities. It is not likely that Congress will take any action on this sort of legislation given their priorities around the budget resolution and new tax laws.

Monitoring new developments

The CTA has been a significant headache for entities and professionals as it’s been turned off and on again and again. It seems that this annoyance is over for the vast majority of us — at least for now. Nevertheless, be mindful of the obligation to report situations where foreigners have ownership interest or control of dually registered entities. Additionally, we’ll continue to monitor the situation and provide any update on the CTA.


ABOUT THE AUTHOR

John Schuman, JD, CFP®

John Schuman, JD, CFP®

Partner, Head of Wealth Transfer at Corient

John is a Partner, Head of Wealth Transfer at Corient, based in our Columbus, OH, office. Previously, he was a Partner, Co-CEO and President of legacy firm Budros, Ruhlin & Roe. As a CERTIFIED FINANCIAL PLANNER™ certificant, licensed attorney and former Certified Public Accountant (CPA), he adds an exceptional perspective to the firm. John’s expertise includes estate planning and taxation, income tax, general business and succession planning, and charitable and retirement planning. He has been a featured speaker at conferences of the Columbus Bar Association, the Financial Planning Association (FPA), the National Association of Personal Financial Advisors (NAPFA), the Ohio CLE Institute, The Columbus Foundation and the International Association of Advisors in Philanthropy.

John holds a Bachelor of Science from The Ohio State University and a Juris Doctorate from Capital University Law School (summa cum laude). John is a member of the Financial Planning Association (FPA), the National Association of Personal Financial Advisors (NAPFA), and the Columbus, State of Ohio and American Bar Associations. He also serves as a member of the Professional Council of The Columbus Foundation.




CONTENT DISCLOSURE

This information is for educational purposes and is not intended to provide, and should not be relied upon for, accounting, legal, tax, insurance, or investment advice. This does not constitute an offer to provide any services, nor a solicitation to purchase securities. The contents are not intended to be advice tailored to any particular person or situation. We believe the information provided is accurate and reliable, but do not warrant it as to completeness or accuracy. This information may include opinions or forecasts, including investment strategies and economic and market conditions; however, there is no guarantee that such opinions or forecasts will prove to be correct, and they also may change without notice. We encourage you to speak with a qualified professional regarding your scenario and the then-current applicable laws and rules. Different types of investments involve degrees of risk, including the loss of principal. The future performance of any investment or wealth management strategy, including those recommended by us, may not be profitable or suitable or prove successful. Past performance is not indicative of future results. One cannot invest directly in an index or benchmark, and those do not reflect the deduction of various fees that would diminish results. Any index or benchmark performance figures are for comparison purposes only, and client account holdings will not directly correspond to any such data. Advisory services are offered through Corient Private Wealth LLC and its affiliates, each being a registered investment adviser (“RIA”) regulated by the U.S. Securities and Exchange Commission (“SEC”). The advisory services are only offered in jurisdictions where the RIA is appropriately registered. The use of the term “registered” does not imply any particular level of skill or training and does not imply any approval by the SEC. For a complete discussion of the scope of advisory services offered, fees, and other disclosures, please review the RIA’s Disclosure Brochure (Form ADV Part 2A) and Form CRS, available upon request from the RIA and online at https://adviserinfo.sec.gov/. We also encourage you to review the RIA’s Privacy Policy and Code of Ethics, which are available upon request