We want to provide a new update regarding the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA).
On January 23, 2025, the U.S. Supreme Court issued a stay of a nationwide injunction previously put in place by a district court in Texas (Texas Top Cop Shop, Inc. v. Garland No. 4:24-CV-478 (E.D. Texas 12/3/24)). Despite this development, it’s important to note that a separate injunction from another Texas court (Smith v. U.S. Department of Treasury (January 7, 2025) U.S. Dist. Court, Eastern Dist. of Texas, Case No. 6:24-CV-336)) remains in place.
The Financial Crimes Enforcement Network (FinCEN) announced on January 25, 2025, that reporting companies covered by the BOI reporting requirement do not have to file the reports (and cannot be penalized for not filing) while an injunction remains in place.
However, any small businesses that fall under the CTA may still choose to submit BOI reports voluntarily.
In legislative developments, two bills, HR 425 and S 100, have been introduced in Congress to repeal the Corporate Transparency Act.
As always, we will stay on top of the fast-changing status of this law and keep you informed of all developments as they occur.