On Tuesday, December 3, 2024, the U.S. District Court for the Eastern District of Texas granted a temporary injunction against the federal government’s Beneficial Ownership Information (BOI) reporting program, on a nationwide basis. Pending a full trial and a full decision on the merits of a permanent injunction, the BOI reporting program is stopped, and the January 1, 2025, deadline does not apply.

We will continue to keep you updated on new developments in this case. 

About the Beneficial Ownership Information Program

The sweeping program — the Beneficial Ownership Information (BOI) program — was established under a bipartisan federal law called the Corporate Transparency Act (CTA). The law has the stated goal of making it “harder for bad actors to hide or benefit from their ill- gotten gains through shell companies or other opaque ownership structures” by forcing companies to disclose the actual human individuals behind them.

This program affects most if not all of the corporations and limited liability companies in which people in the real estate and general business fields are involved, as well as many partnerships, primarily limited partnerships and partnerships that own real estate. It requires each such company, unless exempted under 23 stated FinCEN exemptions, to file an online report to FinCEN, providing certain specified items of information.