The Corporate Transparency Act, R.I.P.

The U.S. Treasury Department has announced that it will not enforce any fines or penalties under the Corporate Transparency Act ("CTA") against U.S. citizens, domestic reporting companies, or their beneficial owners. It will also issue a proposed rulemaking to formally narrow the CTA's reporting requirements to foreign reporting companies only.

Where we were

On February 27, the Treasury Department's Financial Crimes Enforcement Network ("FinCEN") announced that it intended to issue a rule change to extend the CTA's reporting deadlines — and that it would do so before the current deadline (applicable to most companies) of March 21. FinCEN also said it would not enforce the March 21 (or other current) deadlines, including by issuing fines or penalties. Finally, in its February 27 announcement, FinCEN stated that it would initiate a formal process later this year "to minimize burden on small businesses while ensuring that [CTA-reportable "beneficial ownership