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UPDATE: NEW 12/26/24 Court Reversal Means BOI Reporting Again ON HOLD For Now

29 December 2024

Another Fun Holiday Reversal of Position Regarding the CTA and BOIR. 

Since our last post – 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 granting a stay of the preliminary injunction.

What does this mean?

Accordingly, as of December 26, 2024, the injunction issued by the district court in Texas Top Cop Shop, Inc. v. Garland is in effect and reporting companies are NOT currently required to file beneficial ownership information with FinCEN.

At this point, given the lack of clear direction from the courts, we reiterate our position that clients who have not already filed should collect the necessary information required to file a Beneficial Ownership Interest Report (“BOIR”), such that, in the event filings are ultimately once again required, we can quickly and efficiently file BOIRs and ensure client compliance with the Corporate Transparency Act.

At this point we expect the status of CTA filing to remain until at least March 25, 2025, when oral arguments are currently scheduled related to the appeal.

Questions about your specific business entities?

Contact Scott Meyer at 469-916-7700 x115. When It Matters™, you can count on us.

Tags: Corporate Law, Corporate Transparency Act, FinCEN
when it matters™
About Scott A. Meyer

Scott Meyer focuses his practice on Corporate and Intellectual Property matters. His Corporate practice includes a broad spectrum of services including entity formation, business transactions, operational agreements and contracts, sales, acquisitions and mergers of businesses, corporate governance and employment matters.

His Intellectual Property practice includes trademark, licensing and various service agreements for corporations.

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