Corporate Transparency Act - Implementation is Fast Approaching

The Corporate Transparency Act (the “CTA”) is fast approaching implementation. On March 24,

2023, FINCEN (US Treasury Department, Financial Crimes Enforcement Network) published its first set of guidance material intended to aid the public in understanding the upcoming beneficial ownership requirements taking effect on January 1, 2024.

The first set of guidance includes: (i) “Beneficial Ownership - Frequently Asked Questions” (“FAQ”) containing, in particular, illustrative examples of who is, and who is not, a “beneficial owner” under the CTA; (ii) one pagers on key filing dates and key questions; and (iii) introductory and information videos about the reporting requirements.

We issued a tax alert on February 23, 2021, regarding the enactment of the CTA. This tax alert is intended as an update.