On December 3, 2024, a federal district court in Texas issued a preliminary injunction that temporarily blocked enforcement of the Corporate Transparency Act (CTA). This ruling delayed the requirement for companies to submit Beneficial Ownership Information (BOI) to the Treasury Department.
However, on December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit overturned the nationwide injunction, reinstating the enforcement of the CTA. The earlier injunction, part of the Texas Top Cop Shop, Inc. v. Garland case, had paused the obligation for companies to provide Financial Crimes Enforcement Network (FinCEN) with BOI reporting. FinCEN announced that it was extending the initial filing deadline for reporting companies formed before January 1, 2024 to January 13, 2025.
On the evening of December 26, the Fifth Circuit reversed the stay on the temporary injunction against the BOI reporting rule, leaving the injunction in effect while the government’s appeal is reviewed by a three-judge panel. This again makes BOI reporting discretionary nationwide for now. If the injunction is lifted, reporting companies could once more be faced with a short window of time to comply with filing requirements.
This situation continues to develop rapidly. Christianson PLLP will closely monitor updates as the future of BOI reporting unfolds. At this time, we are continuing to file on behalf of all clients who have signed agreements with us. If you have signed an agreement and choose not to file at this time, please contact us immediately. If you do choose to delay filing and updated compliance deadlines coincide with tax season, we cannot guarantee we will have time available to meet the expediated deadline due to the constraints of the demands of our tax busy season.
