On December 26, 2024, a federal court of appeals officially reinstated an injunction blocking the reporting deadline for Beneficial Ownership Information (BOI). This came just days after a panel lifted the injunction. This latest development means that the government cannot enforce the Corporate Transparency Act and BOI reporting requirements, and businesses are under no obligation to file these reports while the court decides the case. Please be mindful that the injunction is only preliminary, and the status of this requirement can change at any time. We recommend that clients should remain ready to file BOI reports even though, presently, the BOI reports do not have to be filed.

Due to the uncertainty of the BOI reporting requirement, for those clients who have asked Pugh Hagan Prahm to complete and file their BOI reports, please continue with completing your BOI worksheet and forwarding a copy of your driver’s license to the appropriate staff person as soon as possible. We will suspend the actual filing of the BOI reports until we have more clarification on the permanency of the Court’s order. Note that even if the injunction remains in place, reporting companies are not precluded from proceeding with their filings if they choose, to avoid future uncertainty.

Please pay attention to additional updates and proceedings in this and other cases which could modify or change the Court’s order.