Here We Go Again… BOI UPDATE

On December 26, 2024, a federal appeals court reinstated a nationwide injunction halting enforcement of Beneficial Ownership Information (BOI) reporting requirements, reversing an order the same court issued earlier this week. Currently, BOI reporting is Voluntary Submission Only. The following is a timeline of events as they currently have taken place in the last month:

• December 3 – The U.S. District Court for the State of Texas issues nationwide injunction of the reporting requirements of the CTA better known as the “Corporate Transparency Act.”
• December 23 – The Fifth Circuit Court “motion panel” issues an order staying the nationwide injunction and ordering expedited argument.
• December 23 – Just hours after the ruling, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issues order adjourning the filing deadline for several categories of Reporting Companies until January 13, 2025.
• December 26 – The Fifth Circuit Court “merits panel” reverses the motion panel’s stay and reinstates the nationwide injunction pending oral argument on appeal.

Visit https://www.fincen.gov/boi for the most recent Alert on this matter.  We will stay on top of any new developments and communicate the same as they are released.

 

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