Beneficial Ownership Information Reporting Blocked Again
Just three days after a U.S. Fifth Circuit Court of Appeals panel lifted the nationwide injunction on the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirements, a different First Circuit Court of Appeals Merits Panel has reinstated the nationwide injunction.
The Timeline:
- December 3, 2024: Texas District Court issues a nationwide injunction on the CTA.
- December 23, 2024: U.S. Fifth Circuit lifts the injunction and the Financial Crimes Enforcement Network (FinCEN) extends the BOI filing deadline to January 13, 2025.
- December 26, 2024: U.S. Fifth Circuit Merits Panel reinstates the nationwide injunction on the CTA.
The BOI reporting requirements under the CTA will continue to be a moving target for business owners. The plaintiffs in the Texas case have requested a review by the full U.S. Fifth Circuit by January 6, 2025 – ahead of the current January 13, 2025, deadline for BOI reporting.
Brown Plus will continue to keep clients posted on the Corporate Transparency Act and BOI reporting requirements. For the latest updates, please visit the Brown Plus Blog: BOI Category page.