12/11/2024
Current update released on 12/6/2024 regarding Beneficial Ownership Information.
Cross References
• Texas Top Cop Shop, Inc. v. Merrick Garland, Attorney General of the United States,
U.S. District Court for the Eastern District of Texas, December 3, 2024.
A Federal District Court Judge for the Eastern District of Texas has issued a preliminary
nationwide injunction on the beneficial ownership information (BOI) reporting rules un-
der the Corporate Transparency Act (CTA) that would have required 32.6 million existing
small businesses to report their beneficial ownership information to the Financial Crimes
Enforcement Network (FinCEN).
The judge stated the CTA is likely unconstitutional as outside of Congress’s power, and
that the injunction should apply nationwide. The judge wrote in part:
“Therefore, the CTA, 31 U.S.C. §5336 is hereby enjoined. Enforcement of the Report-
ing Rule, 31 C.R.R. 1010.380 is also herby enjoined, and the compliance deadline is
stayed under §705 of the APA. Neither may be enforced, and reporting companies
need not comply with the CTA’s January 1, 2025, BOI reporting deadline pending
further order of the Court.”
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