A Texas U.S. Federal Court has placed the mandatory filing of Beneficial Ownership Information Reports (BOI) with the Financial Crimes Enforcement Network (FinCEN) on hold. Thus, the mandatory filing date of January 1, 2025 no longer applies. The case that challenged the filing of BOI, and that has resulted in the elimination of the requirement to file BOI’s on or before January 1, 2025, is Top Cop Shop, Inc. et al, v. Garland, et al..

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., blocking enforcement of the Corporate Transparency Act (“CTA”) and its beneficial owner information (“BOI”) reporting requirements. The case has been appealed and the legal consensus is that the requirement is likely to be reinstated although the mandatory filing date will need to reset in the future.

If you have yet filed your business BOI you may want to wait until the case on appeal plays out. You should discuss whether to file a BOI, notwithstanding the injunction, with your business attorney.

The information presented is not intended to be, and does not constitute, “legal advice.” Because each situation varies, and only brief summary information is provided here, you should not use this information as a basis for action unless you have independently verified with your own counsel that it applies to your particular situation.