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Home | BakerHostetler

New Treasury Statement Nullifies CTA for US Entities

IP Intelligence Report

The Return of ‘Fintiv’? Discretionary Denials of AIA Post-Grant Petitions Are Back on the Menu

Jonathan Forster Talks About Death Taxes on Penn Mutual Podcast

Ann Caresani Speaks at 39th Annual Ohio Employee Ownership Conference

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On March 2, the U.S. Treasury Department <a href="https://home.treasury.gov/news/press-releases/sb0038" target="_blank" rel="noreferrer noopener">issued a press release</a> announcing significant updates to the Corporate Transparency Act (CTA) plans that were <a href="https://www.bakerlaw.com/insights/fincen-to-suspend-cta-enforcement-extend-boi-reporting-deadlines/" target="_blank" rel="noreferrer noopener">announced by the Financial Crimes Enforcement Network (FinCEN)</a> just a few days earlier.

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These updates effectively nullify the CTA for all U.S. reporting companies until further notice.

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The CTA is not dead, but it is hanging by a thread.

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On March 2, the U.S. Treasury Department (the Treasury) <a href="https://home.treasury.gov/news/press-releases/sb0038" target="_blank" rel="noreferrer noopener">issued a press release</a> announcing significant updates to the plans <a href="https://www.bakerlaw.com/insights/fincen-to-suspend-cta-enforcement-extend-boi-reporting-deadlines/" target="_blank" rel="noreferrer noopener">announced by FinCEN</a> just a few days earlier. These updates effectively nullify the CTA for all U.S. reporting companies until further notice:

Indefinite Suspension for U.S. Citizens and Companies:

Extreme Narrowing of the Beneficial Ownership Information (BOI) Reporting Rule:

As a result of these updates, U.S. entities will effectively have no reporting obligations under the CTA unless and until (i) the final revised rules are not as expansive as described in the Treasury’s press release or (ii) the U.S. government announces a subsequent change to its enforcement policy.

As of the time of this publication, FinCEN’s <a href="https://www.fincen.gov/boi" target="_blank" rel="noreferrer noopener">BOI page</a> had not yet been updated to reflect the policy changes signaled by the above announcements.

We will continue to provide updates regarding further material developments as they arise.

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