BOIR Filing put on hold again...

The BOI reporting mandate roller coaster ride continues.

We will continue to update this page until the Beneficial Owner's Information Reporting (BOIR) filing requirements outlined by the Corporate Transparency Act ("CTA") have been resolved. But pay attention as we have seen over the last month, this can change at any point!

Last updated January 3, 2025

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A new panel of the U.S. Fifth Circuit Court of Appeals is reviewing the lower court’s decision to enjoin the enforcement of the beneficial ownership information reporting requirement. (Texas Top Cop Shop, Inc. et al. v. Garland (December 26, 2024) U.S. Ct. of Appeals, Fifth Circuit, Case No. 24-40792) The review will be expedited, but in the interim the new panel reversed the previous panel’s decision to allow the BOI reporting mandate to continue pending the court of appeal’s review.

As the law stands today, penalties cannot be imposed against businesses who fail to file

BOI reports with FinCEN.

However, as we have seen over this last month, this can change at any point. We recommend that you keep an eye on this page as we will update it with the latest developments, as the ultimate decision as to whether to file lies with you. FinCEN has not yet issued any updates on this latest development, but we assume that they will continue to allow businesses to voluntarily file.

Should you choose not to file until you are required to do so, we recommend that you continue to gather all necessary information to be ready to file should the reporting requirement be reinstated. As we saw this past week when the BOI reporting requirement was temporarily reinstated, FinCEN only gave businesses a short extension of the reporting deadlines.

The Court of Appeal’s latest order is available at: