Updated on December 27, 2024
On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reinstated the injunction blocking the BOI reporting deadline. The Department of the Treasury had previously granted an extension until January 13, 2025, for reporting companies created or registered before January 1, 2024.
Key Points:
- The government is currently prohibited from enforcing CTA and BOI reporting requirements.
- This suspension will continue until either the court reaches a final decision or issues a contrary order.
- No compliance is required while the injunction remains in place.
What This Means for Your Business:
Continue to Gather Information
- Despite the suspension, we recommend continuing to collect all required beneficial ownership information.
- Document and verify ownership structures, including all individuals with substantial control or ownership interests.
- Maintain accurate records of company applicants for entities formed after January 1, 2024.
Monitor But Do Not File
- Currently, you are not required to file BOI reports
- The current injunction legally prevents FinCEN from enforcing any reporting deadlines
We will continue to monitor any further developments in this litigation and provide updates as needed. Please contact your Grassi advisor if you have any questions or need assistance in preparing for future BOI requirements.
Click here for direct access to the BIO E-Filing System for additional information.
Categories:
Advisory
