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Corporate Transparency Act Penalties Suspended; New Rulemaking Proposed

On March 2, 2025, and February 27, 2025, the US Department of the Treasury (Treasury) and the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury, made significant announcements regarding the Beneficial...more

Corporate Transparency Act Update: Reporting Obligations Reinstated

On February 18, 2025, the US District Court for the Eastern District of Texas in Smith v. US Department of the Treasury, No. 6:24-cv-336-JDK, entered an order staying (pausing) the nationwide preliminary injunction against...more

Corporate Transparency Act Update: Nationwide Injunction Continues

On January 23, 2025, the Supreme Court of the United States issued a stay of the nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) (31 U.S.C. § 5336) and the Beneficial Ownership...more

Fifth Circuit Reinstates Nationwide Injunction Against Enforcement of the CTA

On December 26, 2024, in response to an emergency motion for rehearing filed by plaintiffs, the US Court of Appeals for the Fifth Circuit reinstated the nationwide preliminary injunction against enforcement of the Corporate...more

Corporate Transparency Act Update: Nationwide Injunction Stayed; Deadlines Extended

On December 23, 2024, in response to an emergency motion by the US Department of Justice, the US Court of Appeals for the Fifth Circuit stayed the nationwide preliminary injunction against enforcement of the Corporate...more

Corporate Transparency Act: What to Know

The Corporate Transparency Act (CTA) introduces beneficial ownership reporting requirements effective January 1, 2024, for new and existing companies. Below is an overview of the new reporting obligations imposed by the CTA....more

West Coast Forum 2023 | Key Takeaways

McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...more

Understanding the Corporate Transparency Act’s Company Reporting Obligations

Beginning January 1, 2024, the US Corporate Transparency Act (CTA) will require “reporting companies” to submit a report to the Financial Crimes Enforcement Network (FinCEN) containing personal information about the reporting...more

IRS Criminal Investigation Division Is on the Hunt for Malta Pension Plan Participants and Promoters

There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011....more

[Webinar] Reporting For Duty: Preparing For the Corporate Transparency Act - July 25th, 1:00 pm - 2:00 pm EDT

The Corporate Transparency Act (CTA) has the potential to reshape the privacy landscape for family offices, while also introducing considerable compliance burdens and legal risk. Join Daniel Bell and Sebastian Orozco...more

Tax Court Tells IRS It Cannot Assess or Collect Certain Tax Penalties

On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax penalties under Internal Revenue Code (Code)...more

Tax Court Rules That the IRS Cannot Assess or Collect Certain Tax Penalties

On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could neither assess tax penalties under Internal Revenue Code (Code) Section 6038(b) against Alon...more

Congress Passes the Corporate Transparency Act with Veto-Proof Majority

On December 11, 2020, and by a veto-proof majority, the US Senate joined the House of Representatives in passing the National Defense Authorization Act for Fiscal Year 2021, which includes the Corporate Transparency Act (the...more

IRS OVDP Ending | Time Is Now for Coming into US Tax Compliance – Especially for Those with Willfulness Issues

The IRS announced on March 13, 2018, that it will begin to ramp down the current OVDP and urged taxpayers with undisclosed foreign assets to apply for the program before it closes on September 28, 2018....more

3/16/2018  /  FBAR , IRS , Offshore Funds , OVDP

IRS Changes Streamlined Filing Compliance Procedures for Non-Willfulness Certification Forms

The Internal Revenue Service (IRS) recently modified the non-willfulness certification form that individual taxpayers must submit to enroll in the streamlined filing compliance procedures (SFCP). SFCP is a program offered by...more

4/6/2016  /  Certifications , FBAR , IRS , Offshore Funds , OVDP

International News: Focus on Private Equity

Our Focus on Private Equity provides a global perspective on some of the challenges being faced by PE firms and how these can be successfully addressed. It also examines some of the many opportunities available, e.g., by...more

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