In another unexpected turn of events in a rapidly evolving legal battle, on December 26, 2024, a new panel of the 5th Circuit Court of Appeals vacated part of a prior panel’s December 23 order, which had lifted the stay on filing Beneficial Ownership Information (BOI) reports. This stay pertains to an ongoing Texas District Court case challenging the constitutionality of the Corporate Transparency Act (CTA). As a result, the court has temporarily barred FinCEN from enforcing BOI reporting requirements. A new notice posted on FinCEN’s BOI website portal confirms that while BOI reports are being accepted, filing remains voluntary.
Beneficial Ownership Information Filings
Although the case has recently seen numerous developments and legal twists, many predict the injunction will remain in place until late March 2025. This nationwide injunction applies to all BOI filings—whether initial reports for newly formed entities, initial reports for companies formed before 2024, or amendments to previously filed reports—regardless of their original due date or any hurricane-related extensions.
Reporting companies and affected individuals should carefully monitor developments and prepare to file if the court lifts the injunction again.
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Check the FinCEN website for more details to ensure your business meets all requirements. If you have any questions, we are here to help. We build value-added relationships with each client to understand their business structure and provide solid solutions. Our approach offers direct access to the firm's decision-makers. Our innovative cross-functional services help businesses address the challenges ahead.