On December 26, the US Fifth Circuit Court of Appeals reversed itself and reimposed a preliminary injunction upon the enforcement of reporting companies’ obligation to file a beneficial ownership information (BOI) report pursuant to the Corporate Transparency Act (“CTA”). As such, at the current time, filing a BOI report is voluntary. While no one knows whether the CTA will ultimately be upheld by the courts, you may wish to consider filing a BOI report in any case, since if the injunction is set aside at any stage, you may be required to file BOI report on very short notice.
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