If you’ve been following the rollercoaster of changes to Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA), you’re likely aware of the ongoing legal battles. Here’s a summary of the current status and what dental practice owners need to know as of early January 2025.
Key Developments in BOI Reporting Requirements
Since early December 2024, BOI enforcement has been caught in a legal tug-of-war, with multiple court rulings and appeals creating uncertainty. Below is a timeline of notable events:
- December 3, 2024: A Texas court issued a preliminary injunction, halting BOI enforcement and raising constitutional concerns about the CTA.
- December 5, 2024: The government appealed the injunction, seeking to reinstate the BOI requirements.
- December 23, 2024: The Fifth Circuit Court briefly lifted the injunction, reinstating the BOI filing deadline. FinCEN responded by extending the due date to January 13, 2025.
- December 26, 2024: The appeals court reimposed the injunction, once again halting enforcement. Oral arguments are set for March 25, 2025.
- January 4, 2025: The U.S. Department of Justice filed a motion with the Supreme Court, requesting it to lift the injunction and allow BOI reporting enforcement to resume. The decision now rests with the Supreme Court, adding yet another layer of uncertainty.
What This Means for Dental Practices
- No Current Obligation to File: Enforcement remains on hold for now, so dental practices are not required to submit BOI reports.
- Optional Filing: FinCEN’s system remains open for voluntary reporting, though no penalties will apply if you choose to wait until enforcement officially resumes.
- Be Prepared: With the DOJ’s appeal now in the Supreme Court’s hands, enforcement could resume at any time. If the injunction is lifted, businesses may be given a short window to comply.
If you have already filed, you are in good shape and shouldn’t need to do anything else regardless of how the courts eventually rule.
Next Steps for Dental Practice Owners
Given the frequent changes and legal uncertainty, dental practice owners should stay informed and ready to act quickly. While there’s no immediate need to file, preparing your BOI information in advance will save time if enforcement resumes abruptly.
We understand the frustration caused by these back-and-forth rulings. Our team is here to provide clarity and guidance, ensuring you’re ready to comply whenever the situation stabilizes. If you have any questions about BOI reporting or would like help gathering your beneficial ownership information, don’t hesitate to reach out.
Stay tuned for more updates, and we’ll keep you informed of any further developments in this ever-evolving situation.