On December 3, 2024, a federal court in Texas issued a nationwide temporary preliminary injunction suspending enforcement of the Corporate Transparency Act, including the Beneficiary Ownership Interest (BOI) report filings. At this time, FinCEN, on its website, has advised that reporting companies are not required to file beneficial ownership information reports, but may do so on a voluntary basis. The Federal government has appealed the temporary injunction.
For the time being, reporting companies are not required to comply with the Corporate Transparency Act reporting requirements and deadlines. The ruling, however, is not a final determination of the Corporate Transparency Act’s constitutionality and enforceability. The ruling only temporarily halts enforcement of the Corporate Transparency Act while the case in the Texas federal Court proceeds.
At this time, Lynn Jackson recommends that owners of entities continue moving forward with collecting of beneficial ownership information for their entities in preparation for filing. Given FinCEN’s position that filings are not currently required, we are advising our clients that they are not required to complete filing with FinCEN at this time but should be ready to file quickly if the injunction is lifted; given the December 31, 2024 filing deadline for most existing entities if the injunction is lifted, there may not be much time to comply. As a result we recommend that entities put themselves in a position to be ready to file as expediently as possible if the injunction is lifted.
If you would like assistance with collecting information for a future filing or completing your filing with FinCEN during this suspended period or have questions about these requirements or changes, please reach out to us immediately so that we may adequately assist and advise you.
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