On December 26, 2024, the Fifth Circuit Court of Appeals merits panel effectively reimposed the nationwide injunction on Beneficial Ownership Information Reports (BOIR) under the Corporate Transparency Act (CTA).
For businesses across the country, this means that all BOIR filing requirements have been suspended until further notice. This leaves businesses with two primary options once again:
i. Wait and see: Hold off on filing BOIRs until the litigation is resolved. If the injunction is lifted, reporting companies will likely be granted a reasonable time to comply, as was the case before.
ii. File proactively: Voluntarily file your BOIR to avoid potential future complications should the requirement be reinstated.
Amid the pendulum swings of recent legal developments, further changes to BOIR reporting remain likely. The status of the injunction could shift again as courts address the constitutional challenges to the CTA.
For more information regarding BOIR filing compliance in light of this new development, please contact Jake Keller at Fonss & Estigarribia LLP at jbk@fellplaw.com and (858) 746-6488.
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