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On December 26, 2024, the United State Court of Appeals for the Fifth Circuit reinstated the preliminary injunction for companies to file BOI Reports with FinCEN pursuant to the Corporate Transparency Act. As a result, there are currently no requirements for Reporting Companies to file BOI reports at this time.
The Fifth Circuit stated that the preliminary injunction will remain in place while that Court considers the constitutionality challenges to the Corporate Transparency Act. The Court has agreed to consider the case on an expedited basis, with briefing to be completed in February of 2025 and oral argument in March.
Reporting Companies should continue to gather the required information to be in a position to file the required Reports if and when the injunction is lifted. Should you need any additional information related to the Corporate Transparency Act, please contact one of our attorneys with expertise in the Corporate Transparency Act:
The case is Texas Top Cop Shop v. Garland, No. 24-40792. Additional updates related to BOI reporting can be found here - https://www.fincen.gov/boi
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