Under the Corporate Transparency Act (CTA), as of Jan. 1, 2024 every “reporting company” must disclose to the Financial Crimes Enforcement Network (FinCEN) information about the reporting company itself, the beneficial owners of that reporting company and, for entities formed or registered after Dec. 31, 2023, up to two company applicants.1 In the vast majority of cases, it will be clear who’s a beneficial owner, but there will also be many instances in which identifying all the
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