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Beneficial Ownership Information

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BOI: Battle Over Injunctions?

As of December 26, 2024: filing deadline is not enforced, but this is likely to change again.

  • December 3, 2024: The U.S. District Court for the Eastern District of Texas issued an order enjoining enforcement of the Corporate Transparency Act (CTA) and its Reporting Rule. (Texas Top Cop Shop, Inc. v. Garland, No. 4:24-CV-478, 2024).
  • December 5, 2024: The same court denied the Government's motion to stay the preliminary injunction. (Texas Top Cop Shop, Inc. v. Garland, 2024 WL 5049220).

  • December 17, 2024: The district court again denied the Government's request to lift the injunction, leaving the CTA's enforcement blocked. (Texas Top Cop Shop, Inc. v. Garland, 2024 WL 5145951).

  • December 23, 2024: A motions panel of the Fifth Circuit Court of Appeals granted the Government’s emergency motion for a stay pending appeal, effectively reinstating the enforcement of the CTA and Reporting Rule. The panel also expedited the appeal for the next available oral argument. (Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, 2024 WL 5203138).

  • December 26, 2024: The Fifth Circuit Court issued an order vacating the motions-panel's stay that had allowed enforcement of the CTA. This decision reinstated the district court's injunction, pausing enforcement again. The appeal remains expedited, and a briefing schedule is forthcoming. (https://www.ca5.uscourts.gov/opinions/unpub/24/24-40792..pdf<)

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Understanding the Beneficial Ownership Information (BOI) Reporting Requirements: What Small Businesses Need to Know

As the Financial Crimes Enforcement Network (FinCEN) ramps up its outreach efforts, it's crucial for small business owners and self-employed individuals to stay informed about the Beneficial Ownership Information (BOI) reporting requirements. With the Corporate Transparency Act (CTA) now in full effect, over 32 million businesses are required to report detailed information about their beneficial owners. Here’s what you need to know to ensure compliance and avoid costly penalties.

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