CURRENT STATUS: No BOI reporting is necessary

December 27, 2024

By Ron Lefebvre and Mark Fischer

As we previously wrote, the 2021 Corporate Transparency Act (CTA) required most businesses to file a Beneficial Ownership Information (BOI) report with the Financial Crimes Enforcement Network (FinCEN) on or before January 1, 2025.

On December 3, 2024, however, a federal district court in Texas immediately suspended the enforcement of the CTA on a nationwide basis. You can read more about that decision in our prior post, here: https://www.ymfzlaw.com/boi-filings-suspended/.

Then, on December 23, 2024, the United States Court of Appeals for the Fifth Circuit granted the government parties’ emergency motion to stay the suspension of CTA enforcement while the appeal is being heard. As a result, the filing requirement has been reinstated pending further decision of the Court. In response to this ruling,

FINCEN (the agency handling BOI reporting) issued a notice extending the BOI filing deadline to January 13, 2025.

However, just a few days later, on December 26, 2024, the Fifth Circuit reversed itself. The Fifth Circuit entered an order holding that: while the government parties’ appeal of the Texas district court’s order was pending before it, the BOI reporting requirement would remain suspended.

That means that, as of today, businesses do not have to file BOI reports pursuant to the end-of-year deadline, until we receive further rulings from the Fifth Circuit.

Please contact our firm if you would like assistance with respect to these compliance matters.