Beneficial Ownership Reporting Reversals
On December 23rd, 2024, the Fifth Circuit Court of Appeals suspended the lower court’s preliminary injunction against the Beneficial Ownership (BOI) reporting mandate. This temporarily put the reporting requirements back into effect– until four days later, when on December 27th a new Fifth Circuit panel reversed the December 23rd decision.
As of the date this newsletter, there will be no penalties assessed against businesses that decline to submit timely BOI filings with FinCEN. However, the Court of Appeals has promised an expedited review, and the situation may again change on a moment’s notice. We recommend that any clients with BOI filing requirements who have not already submitted their reports be prepared upon final decision. This includes determining what information would need to be included and gathering all necessary documents.
We will continue to monitor developments and provide updates as they become available. Please reach out to your attorney or DKC representative if you have any questions.