Your Business Layer should have nothing to do with the presentation layer - it shouldn't even know that it's a Winforms app, a Console app, or a web app. Heck, the BL may not even by running on the same computer as the PL or DL!
Instead, if the BL (or DL) has rules which require an action from higher layers, they should provide Events that higher layers can handle. The event handler then closes teh forms as needed so that OOPs principles aren't compromised.
Have a look here:
Transferring information between two forms, Part 2: Child to Parent[
^] - it's designed for forms, but it's exactly the same process for layers (and the separate Projects / Assemblies they are made of)