Merry Christmas from the 5th Circuit!
Late yesterday, the Fifth Circuit Court of Appeals granted a stay over the injunction issued by the U.S. District Court for the Eastern District of Texas ealier this month halting the filing of BOI reports, and issued a court order reinstating the January 1, 2025 BOI filing deadline under the CTA. Due to the ruling, all non-exempt entities were required to file BOI reports prior to the January 1, 2025 deadline. However, in response to the ruling, the Financial Crimes Enforcement Network (“FinCEN”) extended the deadline to file BOI reports to January 13, 2025.
The lower court previously ruled that the CTA was unconstitutional, resulting in the belief that BOI reports were not required. This new appellate ruling overturns the prior injunction, giving reporting entities a short window to report their BOI. We strongly recommend that all required entities proceed to file BOI reports prior to the new January 13, 2025 deadline.
Happy New Year!