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We last wrote about the Corporate Transparency Act (CTA) in the July/August 2023 issue of Trusts & Estates, when we were still months away from its Jan. 1, 2024 effective date. A lot has transpired since then, including recent constitutional challenges to the CTA and the Financial Crimes Enforcement Network’s (FinCEN) periodic updates in the form of FAQs. We’ll discuss these updates and their implications for entities deciding how and when they should file.
CTA Overview
The CTA was enacted in 2021 as part of the National Defense Authorization Act and is the latest extension of the anti-terror and money laundering programs of the Patriot Act. It was scheduled to be effective on Jan. 1, 2024 and went live then despite numerous calls for a ...
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