Articles
What’s Happening at BLCO
President Signs Sweeping Reconciliation Bill (OBBBA)
One day after the House voted 218 to 214 3 to approve the Senate-passed reconciliation bill, on July 4th President Trump signed into law H.R. 1 the “One Big Beautiful Bill Act (OBBBA.)” As with any tax legislation, the devil is in the details. In addition to the summary below, we will have further updates concerning specific items such as effective dates for each provision, income limitations, and any detailed Treasury Regulations that may follow.
Corporations: New PA Annual Reports due June 30, 2025
As we mentioned earlier this year, beginning in 2025, the Pennsylvania Department of State (DOS) instituted a new annual report requirement. All domestic (PA) and foreign (non-PA) based entities doing business within the Commonwealth must register and file online to report basic company information. For-profit entities must also pay a small fee of $7. There is no fee for non-profits.
BOI Update: Filing Requirements Reinstated
Here is the latest update on BOI reporting from the FINCEN: With the February 18, 2025, decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.), beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect.
However, because the Department of the Treasury recognizes that reporting companies may need additional time to comply with their BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025, for most companies.
UPDATE: BOI FILING INJUCTION CHALLENGED BY DOJ
As previously reported, on 12/3/24 a federal district court in Texas issued an order halting the enforcement of the Corporate Transparency Act (CTA) along with the requirement to file Beneficial Ownership information (BOI) reports with the Financial Crimes Enforcement Network (FINCEN.).
The court’s injunction, issued in Texas Top Cop Shop, Inc. vs. Garland, applies nationwide. FINCEN has indicated it will comply with the injunction and BOI reporting is currently voluntary.
UPDATE: BOI report filing suspended indefinitely
On 12/3/24 a federal district court in Texas issued an order halting the enforcement of the Corporate Transparency Act (CTA) along with the Beneficial Ownership information (BOI) reporting rules contained in its regulations. The court’s injunction, issued in Texas Top Cop Shop, Inc. vs. Garland, applies nationwide.
The injunction states that the CTA and the BOI reporting rule will not be enforced, and companies formed before 2024 need not comply with the Jan. 1, 2025 deadline until the matter is further adjudicated. Penalties for noncompliance will also not be imposed on newly formed companies with the shorter 90-day and 30-day filing thresholds during this stay.
Buckno Lisicky will continue to keep you updated with further developments.