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Important BOI Reporting Update

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Posted by BOOSCPA Strategic Tax Services Group Posted on Dec 16 2024
Corporate Transparency Act — Beneficial Ownership Information Reporting Requirement
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This is a follow-up to our previous post regarding the Corporate Transparency Act (CTA). On Tuesday, December 3, 2024, a federal district court in Texas issued an order granting a nationwide, preliminary injunction that: (1) enjoins enforcement of the Corporate Transparency Act (CTA) and regulations implementing its beneficial ownership information (BOI) reporting requirements, and (2) stays all deadlines to comply with the CTA’s reporting requirements, including the January 1, 2025 deadline for reporting companies to submit their initial BOI report. The Department of Justice, on behalf of the Department of the Treasury, filed an appeal of the district court’s decision on December 5, 2024.

The Financial Crimes Enforcement Network (FinCEN) has responded that as long as the preliminary injunction remains in effect:

  • reporting companies are not required to report BOI to FinCEN; and
  • reporting companies will not be subject to liability for failing to report their BOI.


    • FinCEN also indicated that reporting companies may continue to voluntarily submit BOI reports.

    The future of the CTA and BOI reporting, including when reports need to be submitted, remains fluid and unpredictable. While the Texas district court’s ruling may be the most recent decision issued, it is not the only case in which the CTA has been challenged. Federal district court decisions on the validity of the CTA have conflicted, and three district court cases are currently being appealed to their respective Courts of Appeals.

    Given the ongoing developments and uncertainties, it is strongly advised that you continue to closely monitor the situation and be prepared to respond swiftly if necessary. We will keep you informed of any significant updates.

    Thank you for your attention to this matter, and please feel free to reach out if you have any questions or concerns.