It was about 5:30 p.m. PT last Friday, March 21, 2025, and I was about to sign off from my computer after a long week and turn my attention to college basketball, when I received an email from FinCEN. The message was that FinCEN had issued an interim final rule relative to the Corporate Transparency Act (“CTA”).
I am embarrassed to admit that my curiosity got the best of me. Rather than jump into a weekend of exciting college basketball, I chose to read the 36-page interim final rule (the “IFR”). Yes, I am a bit consumed with the saga of the CTA. However, thanks to my cable provider, my DVR had been busy all day recording the games. So, after scouring the IFR, I was able to enjoy a late night of college hoops.
I was hoping to take a short breather from covering the Corporate Transparency Act (“CTA”). However, I am getting several inquiries from attorneys and business owners, asking if they have missed anything with respect to the CTA and more specifically whether the CTA is dead or alive. Accordingly, I decided to provide readers with a brief update.
I apologize in advance if this report creates stress or anxiety. Unfortunately, this entire ordeal has created unrest for business owners and their advisers. We continue to hope that the saga will come to an end.
If you feel punch-drunk from the rapid-fire updates to the Corporate Transparency Act (“CTA”), you are not alone. It is hard to keep up with the madness surrounding this law.
Hoping not to stupefy readers, I will address what I believe is the latest major development in the life of the CTA. The Treasury made an earth-shattering announcement this past Sunday that can be broken down into the following two bite-size components:
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Larry J. Brant
Editor
Larry J. Brant is a Shareholder and the Chair of the Tax & Benefits practice group at Foster Garvey, a law firm based out of the Pacific Northwest, with offices in Seattle, Washington; Portland, Oregon; Washington, D.C.; New York, New York, Spokane, Washington; Tulsa, Oklahoma; and Beijing, China. Mr. Brant is licensed to practice in Oregon and Washington. His practice focuses on tax, tax controversy and transactions. Mr. Brant is a past Chair of the Oregon State Bar Taxation Section. He was the long-term Chair of the Oregon Tax Institute, and is currently a member of the Board of Directors of the Portland Tax Forum. Mr. Brant has served as an adjunct professor, teaching corporate taxation, at Northwestern School of Law, Lewis and Clark College. He is an Expert Contributor to Thomson Reuters Checkpoint Catalyst. Mr. Brant is a Fellow in the American College of Tax Counsel. He publishes articles on numerous income tax issues, including Taxation of S Corporations, Reasonable Compensation, Circular 230, Worker Classification, IRC § 1031 Exchanges, Choice of Entity, Entity Tax Classification, and State and Local Taxation. Mr. Brant is a frequent lecturer at local, regional and national tax and business conferences for CPAs and attorneys. He was the 2015 Recipient of the Oregon State Bar Tax Section Award of Merit.
