Over the holiday break two panels in the U.S Court of Appeals for the Fifth Circuit issued different and opposing orders regarding Beneficial Ownership Information Reporting. The first panel ruled on December 23rd to require reporting. This was immediately followed by an alert from the Treasury notifying the public of extended deadlines for compliance.

Just three days later, on December 26th, the second panel overruled that decision causing confusion for reporting companies throughout the country.

Currently, reporting companies are NOT currently required to file beneficial ownership information with FinCEN, however, voluntary filings are still accepted. (FinCEN, 2025)

Stay tuned… there is still plenty of litigation pending over the Corporate Transparency Act and BOI reporting rule.