BOI Reporting: Another Court Ruling Halts Implementation
BOI Reporting: Another Court Ruling Halts Implementation, Uncertainty Remains as Legal Challenges Continue
With a flurry of activity in the days leading up to the holiday season and the new year, the U.S. Court of Appeals for the 5th Circuit issued a ruling on December 26, 2024, that Beneficial Ownership Information (BOI) reporting is, once again, on hold.

The next hearing on the BOI reporting is scheduled for March 25, 2025. We hope this hearing will decide BOI reporting and requirements once and for all, but additional hearings and uncertainty could follow. BOI reporting is trying to be established by the Financial Crimes Enforcement Network (FinCEN). But this ongoing legal battle has seen several shifts, with courts previously blocking and then reinstating the requirement.
The current ruling exempts reporting companies from the obligation to file BOI reports, though they may still do so voluntarily. FinCEN has assured businesses that they will not face penalties or fines during the judicial review of this matter.
The BOI reporting regulation, if ultimately upheld, would necessitate most businesses to disclose individuals with direct or indirect ownership exceeding 25% or those who exert control over the company. This information is intended to assist law enforcement agencies in combating money laundering, terrorism financing, and other financial crimes.
Disclaimer: This article provides general information and should not be considered professional financial or tax advice. Please consult with a qualified CPA or financial advisor for guidance specific to your individual business needs.
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Adam manages a variety of tax and accounting engagements for business clients in numerous industries, including manufacturing, real estate, construction, alternative investments, and professional services. He has experience in federal tax, multi-state corporate income and franchise tax, and municipal income tax. In addition to his tax compliance background, Adam specializes in preparing and managing complex partnership engagements.
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Deadline Looming: Beneficial Ownership Information (BOI) – November 19, 2024
Corporate Transparency Act: What Businesses are Affected? – January 2, 2024
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