In the never-ending saga of the Corporate Transparency Act (“CTA”), the beneficial ownership information (“BOI”) rule has been reinstated with the first filing due March 21, 2025, for companies formed before January 1, 2024.

As a refresher on the CTA’s chronicle, in December, a Texas District Court halted the implementation of the BOI reporting. Two weeks later, the national injunction was stayed by a circuit court; four days after that, the same circuit court vacated the stay, bringing the BOI reports to a standstill. Since December, courts have been deliberating about the fate of this contentious rule.

At this time, firms should inventory all entities (including SPVs) within their organizational structure to determine whether any exemptions can be met or which entities will require filings.

Please contact Orical to discuss which entities, if any, will need filings or to facilitate these.