Important Updates on BOI Filing Requirements and the Corporate Transparency Act

As businesses navigate the changing landscape of the Corporate Transparency Act (CTA) and the Beneficial Ownership Information (BOI) filing requirements, it's crucial to stay informed of the latest developments. Below, we've summarized recent updates and provided clarity on what they mean for your reporting obligations.


Key Updates:

12/31/2024

The Department of Justice has filed to stay the preliminary injunction with the Supreme Court. There is no clear indication when the Supreme Court will rule on this filing. See the article from Journal of Accountancy here.


12/27/2024


The Fifth Circuit Court issued an expedited briefing schedule. Oral arguments regarding the constitutionality of the Corporate Transparency Act’s Beneficial Ownership Reporting requirement are scheduled for March 25, 2025.



12/26/2024


The Fifth Circuit Court of Appeals convened an En Banc Session and reinstated the nationwide preliminary injunction. This ruling pauses the BOI filing requirement until the case is resolved. FinCEN’s updated alert clarifies that:

  • Companies are not currently required to file BOI reports.

  • There is no liability for failing to file while the injunction is in place.

  • Companies may choose to submit reports during this period voluntarily.


12/23/2024


The Fifth Circuit Court of Appeals granted a motion to lift the preliminary injunction, reinstating the BOI filing requirement. In response, FinCEN issued an alert granting reporting companies additional time to comply. Companies initially required to file by January 1, 2025, now have until January 13, 2025, to submit their initial BOI reports.


12/03/2024

The Fifth Circuit Court in East Texas issued a preliminary nationwide injunction prohibiting the Financial Crimes Enforcement Network (FinCEN) from enforcing the Beneficial Owner Information (BOI) Reporting Requirement. The court ruling found that the requirement was “likely unconstitutional”.


Stay Updated

We understand how critical these developments are to your compliance efforts. This page will be regularly updated as new information becomes available, so please check back often for the latest updates on BOI requirements and the CTA.

Our team is here to help you navigate these changes and ensure you meet your compliance obligations. Don’t hesitate to reach out with questions or concerns.


For more information about BOI reporting in general please click here. 

If you’d like our assistance with your BOI Report filing, please email us at boi@usxa.com. If you’ve already engaged us to assist, we’ll contact you individually soon to discuss any necessary remaining steps to complete your filing.