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UPDATE: March 5, 2025: BOI filings have been effectively paused for the foreseeable future. There will be no enforcement until FinCEN Issues new rules.
UPDATE: February 24, 2025 - BOI Filings are back on after the Texas Injunction was lifted on February 18. Most companies have until March 21, 2025 to file.
A lot has happened but nothing has changed since our last update - enforcement of the Corporate Transparency Act is still blocked by court order. Companies who have already filed their BOI report do not need to do anything. Companies who have not filed can choose to voluntarily file or take a wait and see approach
On December 26, 2024, the United States Court of Appeals for the Fifth Circuit in the case of Texas Top Cop Shop, Inc., et al. v. Garland barred enforcement of the Corporate Transparency Act (CTA). The government appealed to the United States Supreme Court. On January 23, 2025, the Supreme Court granted the government’s application, lifting the injunction that was blocking enforcement of the CTA. However, the Supreme Court’s order did not affect a separate nationwide injunction issued by a different federal judge in Smith v. U.S. Department of the Treasury.