NEW UPDATE 12/27/24 (10 a.m. CT):
A new fifth circuit decision has once again suspended Beneficial Ownership Information filing requirements under the Corporate Transparency Act. This lifts the requirement for many business owners who were required to file by Jan. 13, 2025. It vacates a Dec. 23, 2024, by the Court of Appeals for the Fifth Circuit, which then issued a temporary stay on the nationwide injunction.
This is a fast-developing issue. Although reporting requirements for business owners are again suspended, it's highly recommended that owners continue to gather all relevant information and be prepared to submit their report(s) in the event of the injunction once again being lifted.
Find more information at https://fincen.gov/boi.
NEW UPDATE 12/23/24:
Beneficial Ownership Information filing requirements under the Corporate Transparency Act are once again in effect, with many business owners required to file by Jan. 13, 2025. This is the result of an action on Dec. 23, 2024, by the Court of Appeals for the Fifth Circuit, which issued a temporary stay on the nationwide injunction.
Find more information at https://fincen.gov/boi.
UPDATE 12/5/24: Beneficial Ownership Information reporting requirements suspended after court injunction
The U.S. District Court for the Eastern District of Texas issued a preliminary injunction Dec. 3, 2024, against enforcement of the Corporate Transparency Act throughout the entire United States.
Many business entities subject to the Corporate Transparency Act were required to register basic information with the US Treasury Department by Jan. 1, 2025, known as Beneficial Ownership Information (BOI). This reporting requirement under the Corporate Transparency Act is now suspended until further action has been taken by a higher federal court.
Owners of corporations, limited liability companies, limited partnerships, and some other business entities can still register with the U.S. Treasury Department under the Corporate Transparency Act but at this time are no longer legally required to do so.
Business owners who are required to register but have not yet done so should keep in touch with their attorney regarding the latest developments of the Corporate Transparency Act litigation. Owners should also continue to gather the information needed for registration in case the injunction is lifted leaving only a short timeline for compliance.
For additional information, see: Texas federal judge issues nationwide injunction, suspends business ownership reporting requirements
—Dave Aiken, Agricultural Law and Water Law Specialist, Center for Agricultural Profitability
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