United States: Beneficial Ownership Reporting, Part III

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    October 2022 tax news and trends

    in a nutshell

    On September 29, 2022, FinCEN published a final rule on beneficial owner information reporting requirements (seefinal ruleImplement beneficial owner information reporting provisions of the Corporate Transparency Act (CTA). In our previous Client Alerts, Beneficial Ownership Reporting Updates in the United States and Beneficial Ownership Reporting Part II, we discussed the implications of the CTA and proposed regulations. Here, we summarize the final rule and pay particular attention to the changes FinCEN made to the proposed rule.

    On September 29, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) (“Ministry of Finance“) has issued a final rule on beneficial owner information reporting requirements (“final rule), implementing the beneficial owner information reporting provisions of the Corporate Transparency Act (CTA). You must report information about “persons” to FinCEN.

    The final rule largely tracks previous proposed rules issued by FinCEN on December 8, 2021 (seeProposed regulationsHowever, we have included some changes to “Company Applicants” and reporting timings that companies can welcome. The final rule he is effective January 1, 2024.

    In our previous Client Alerts, Beneficial Ownership Reporting Updates in the United States and Beneficial Ownership Reporting Part II, we discussed the implications of the CTA and proposed regulations. Below is a summary of the final rule, with particular attention to the changes FinCEN made to the proposed rule.

    Click here to access the full alert.


    author
    Lyubomir Georgiev

    Ljubomir Georgiev has practiced law in the United States and Switzerland since 2003. He has assisted banks, insurance companies, trustees, family offices, wealth managers and high net worth individuals. Ljubomir participated in the negotiation of a special arrangement between the Government of the Principality of Liechtenstein and the United Kingdom regarding voluntary disclosure, certification of tax compliance and exchange of tax information. He is Head of International Tax and Global Wealth Management in Zurich. Lyubomir has worked in Washington DC and New York. Previously, he was a member of the EMEA Wealth Management Steering Committee and was responsible for Knowledge Management and Training. Lübomir is admitted to practice as a foreign-qualified attorney in Washington, DC, the US Tax Court, England and Wales, and Switzerland. Since 2012, he has been ranked by Chambers Global as a foreign expert in practice areas such as UK tax and private clients, US private clients, Liechtenstein tax and general business law.



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