Resource Library
Ezkovich & Co. is pleased to provide these resources to our clients and the general public. Please remember that none of these resources is, or should ever be considered, as legal advice, and that the reader should always consult with the attorney of their choice for any legal advice. These resources are informational only.
Beneficial Ownership Information Reporting Requirement (BOIRR | CTA)
The following materials relate to the United States Treasury's Beneficial Ownership Information Reporting Requirements, or BOIRR, and also known as the Corporate Transparency Act, or CTA.
IMPORTANT NOTICE: As of March 2, 2025, Treasury has indefinitely SUSPENDED the enforcement of all fines and penalties. Treasury has not ended the actual requirement to file BOIRR reports.
THIS ISSUE REMAINS IN FLUX. Please review the important Updates that appear below.
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1. Ezkovich & Co.'s White Paper on Beneficial Onwership Information Reporting Requirements
2. Statutory Basis, 31 U.S.C. 5336
3. Regulatory Basis (Rules), 15 C.F.R. 1010.380
4. Nationwide Injunction Issued [Texas Top Cop v Garland] December 3, 2024
5. Updates.
➤ UPDATE J. BOIRR Update, March 18, 2025 - Treasury Suspends Enforcement of Fines and Penalties
◆ Document J.1 Treasury Press Release 2025-0302.
◆ Document J.2 February 27, 2025, Press Release with Filing Deadline.
◆ Document J.3 Filing Deadline Screenshot 2025-0318.
◆ Document J.4 Beneficial Ownership Information Reporting Requirement as of March 18, 2025.
➤ UPDATE I. BOIRR Update, February 20, 2025 - Treasury States BOIRR Filings ARE Again Required (For Now)
◆ Document I.1 Treasury Alert FIN-2025-CTA1 2025-0218.
◆ Document I.2 Smith v US, District Court Order Staying Its Injunction.
UPDATE H. BOIRR Update, February 7, 2025 - Treasury States BOIRR Filings Are Still Not Required (for now)
◆ Document H.1 - Treasury Alert (as viewed 020625).
UPDATE G. BOIRR Update, January 30, 2025 - Supreme Court Cancels Injunction, but BOIRR Filings Are Still NOT Required (for now)
◆ Document G.1 Supreme Court Order Cancelling Nationwide Injunction January 24, 2025
◆ Document G.2 Treasury Continues Suspension of BOIRR Filing Deadlines For Now January 24, 2025
◆ Document G.3 Smith v. US Treasury - Injunction issued January 7 2025
UPDATE F. BOIRR Update, December 30, 2024 - Appellate Court VACATES its Earlier Order: BOIRR Filing Not Required (for now)
◆ Document F.1 Appellate Court Order Reinstating the Injunction, December 27, 2024
◆ Document F.2 Treasury Suspends BOIRR Filing Deadlines For Now
UPDATE E. BOIRR Update, December 24, 2024 - Appellate Court GRANTS Government Request to Stay Injunction || New Filing Deadline Issued by Treasury is January 13, 2025
◆ Document E.1 Appellate Court Order Granting Government's Motion to Stay Injunction issued by the Court on December 23, 2024
◆ Document E.2 Treasury Extends Certain BOIRR Filing Deadlines
UPDATE D(i).BOIRR Informational Update, December 23, 2024 - Congress did not enact any changes to the BOIRR Act
UPDATE D. BOIRR Informational Update, December 20, 2024 - Proposed Legislation
◆ Document D.1 Excerpt of failed House Resolution
UPDATE C. BOIRR Update, December 17, 2024 - District Court Denies Government Request to Keep January 1 Deadline
◆ Document C.1 Denial of Government's Motion to Stay Injunction issued by the Court on December 17, 2024
UPDATE B. BOIRR Update, December 11, 2024 - Government Seeks to Keep January 1 Deadline
◆ Document B.1 Motion to Stay Injunction filed by Treasury, December 11, 2024
60UPDATE A. BOIRR Update, December 9, 2024
◆ Document A.1 Amended Nationwide Injunction, December 5, 2024
◆ Document A.2 Amended Notice of Appeal filed by Treasury, December 5, 2024