Over the past few weeks, there has been a lot of back-and-forth drama surrounding the BOI reporting requirements. Here’s what you need to know: 
- As of 1/24/2025, FinCEN confirmed it is not currently enforcing BOI reporting rules in consideration of the nationwide order issued in the case Smith v. U.S. Department of the Treasury.
- This means businesses are not required to submit initial or updated BOI reports at this time; however, any business that chooses not to file should remain alert for changes in the reporting rules.
- The Smith case is separate from the Texas Top Cop Shop matter which issued a nationwide injunction in December 2024.
- That Texas Top Cop Shop injunction was lifted by the U.S. Supreme Court in an order on 1/23/25; however, the Smith order remains in effect and has not yet been appealed.
What’s next?
BOI reporting under the Corporate Transparency Act remains the subject of pending litigation and proposed legislation. Stay tuned for further updates and be prepared to file if the situation changes.
Resources
For more about the CTA and BOI reporting, including a description of BOI reporting and who is impacted, see our previous articles.
BOI Injunction Reinstated, Reporting Paused Again – HW&Co. CPAs and Advisors
New Reporting Requirement for Businesses – HW&Co. CPAs and Advisors
New CTA Requirements for LLC Owners – HW&Co. CPAs and Advisors
Alert: Does BOI Reporting Apply to Your Business? – HW&Co. CPAs and Advisors
And view our recent webinar: BOI: Are You Ready? – HW&Co. CPAs and Advisor
If you have questions about how the BOI reporting rules impact your business, please contact your advisor.
