Attorney Racheal M. Holland will be presenting at the Real Property Law seminar on February 24 & 25, 2020.
On December 3, 2024, a federal district court in the Eastern District of Texas granted a nationwide injunction, enjoining government enforcement of both the Corporate Transparency Act and the associated reporting rule requirements (i.e. BOI or Beneficial Ownership Information reporting). On December 5, 2024, a Notice of Appeal was filed, and a stay of the injunction was requested pending that appeal.
On December 23, 2024, a panel of the U.S. Court of Appeals for the Fifth Circuit granted a stay of the district court’s preliminary injunction but on December 26, 2024, a different panel of the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the Court’s December 23, 2024, order. Thus, as of December 26, 2024, the injunction is in effect and reporting companies are not currently required to file beneficial ownership information with FinCEN.
It would be well to be prepared to comply with the BOI reporting rule until a final determination is made by the Courts, but until further notice, the mandatory reporting to the Financial Crimes Enforcement Network by “Reporting Companies” is suspended.
See FINCEN's website for the latest Alert: https://fincen.gov/boi
If you have questions, please contact your attorney.