On December 26, the Fifth Circuit Court of Appeals reinstated a lower court’s injunction that temporarily blocks the enforcement of beneficial ownership information (BOI) reporting requirements outlined in the Corporate Transparency Act (CTA) and administered by the Financial Crimes Enforcement Network (FinCEN). This decision reverses an earlier order issued by the court earlier in the week, aiming to “preserve the constitutional status quo while the merits panel reviews the parties’ substantive arguments.”
The AICPA, CTCPA, and several state CPA associations have been advocating for the federal government to delay the original BOI reporting deadline of January 1, 2025, by at least one year. While these organizations await further clarification from FinCEN, professionals assisting clients with BOI filings are encouraged to continue collecting necessary information and remain prepared to file in case the injunction is lifted.