Halt the BOI Reporting Presses -AGAIN!

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BOI Halted again

BOI Report Filing Paused Again on December 26, 2024

In yet another twist for the Corporate Transparency Act (CTA) the 5th Circuit Court of Appeals just halted enforcement on Beneficial Ownership Information reporting. Businesses are currently NOT subject to the January 13 Reporting Rule deadline set on December 23, 2024, that would have required corporate and personal information to be disclosed to the government. In the effect you are confused, this is a U-turn a mere three days after another panel of the same appeals court revived the reporting requirements.

The formal decree from the Financial Crimes Enforcement Network states reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.

History of CTA and BOI Reporting

  • 2021: Congress passed the Corporate Transparency Act and set a January 1, 2025, deadline for BOI reporting obligations.
  • 12/3/2024: A Texas federal court issued an injunction halting the CTA’s reporting obligations.
  • 12/23/2024: Motions panel of the 5th Circuit overturned the injunction, reviving the CTA. The government responded by postponing the reporting deadline until January 13, 2025.
  • 12/26/2024: Another 5th Circuit panel reinstated the nationwide injunction, citing the need to preserve the status quo while it reviews the substantive arguments in an expedited appeal.
  • 3/25/2025: The 5th Circuit will hear arguments with briefing schedules set for February.

All this is to say that due to this latest development, reporting companies are NOT currently required to submit beneficial ownership information (BOI) reports. This includes the initial reports for entities formed before January 1, 2024, that were due by January 13, 2025.

The U.S. Financial Crimes Enforcement Network (FinCEN) has indicated that companies may opt to submit BOI reports voluntarily if they choose.

While compliance obligations are currently on hold, the CTA’s requirements could once again be reinstated by future court rulings

The topic of Beneficial Ownership Information reporting has zig-zagged through many changes over the past year. We continue to share relevant news to keep you abreast of the important notices. Contact us at info@madonia.com or (312) 578-9300 with questions, concerns or to file your BOI report.