On December 26, 2024, a Fifth Circuit panel reinstated a nationwide injunction blocking the enforcement of the Corporate Transparency Act (CTA), just three days after they lifted the injunction originally imposed by a Texas district court.
As a result, the enforcement of the CTA is temporarily on hold again. Meaning, that at present the requirement to file your BOI report(s) is on hold.
This recent development has significant implications for determining whether BOI reports will be required again in the future.
Due to the numerous recent rulings surrounding BOI reporting, we currently do not have a strong recommendation on whether businesses should proceed with filing given the ongoing uncertainty.
However, we encourage you to contact us as soon as possible if you would like to move forward with filing. If you have previously contacted us about this filing, we will be reaching out to you.
Please note that this development is recent, and more information is unlikely to be available until FinCEN shares an update or files the appeal.
We will provide future updates as the situation progresses.