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The Corporate Transparency Act Six Months InThe Corporate Transparency Act Six Months In

Despite hope for overturn or repeal, prepare to file on time.

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12 Min Read
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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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About the Authors

Domingo P. Such III

Domingo P. Such, III is Firmwide Co-Chair of the Family Office Services practice at law firm Perkins Coie LLP, based in the Chicago office. He uses his background as a skilled lawyer, as well as his MBA education and business acumen, to advise businesses, wealthy families and high-net worth individuals on a range of matters included contested issues. Mr. Such has provided counsel over the past two decades on income, gift, estate and generation-skipping transfer tax planning matters; charitable giving; and planning for succession of ownership during life and at death through estates, trusts and family office entities. He can be reached at [email protected].

Jamie A. Schafer

Partner, Perkins Coie

Jamie A. Schafer is a partner at Perkins Coie, based in Washington, D.C.

Gerard F. Joyce

National head of Trusts & Estates, Fiduciary Trust International

Gerard F. Joyce, Jr. is national head of trust & estates at Fiduciary Trust International. Mr. Joyce, who is based in New York, oversees the firm’s trust and estates strategy and administration in the U.S.