News & Analysis as of

Subsidiaries Exemptions

Holland & Knight LLP

The (Uncertain) Application of the Corporate Transparency Act to Tribal Entities

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The Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of the Treasury (Treasury Department) charged with administering the Corporate Transparency Act (the CTA), on Aug. 1, 2024, held a Tribal...more

Holland & Knight LLP

FinCEN Issues New Guidance on Reporting Company Filing Requirements

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 8, 2024, issued additional FAQs1 providing guidance on Reporting Company filing requirements under the Corporate Transparency Act...more

Womble Bond Dickinson

The Impact of the Corporate Transparency Act on Companies in a Captive Insurance Structure

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Captive insurance companies are likely exempt from filing a Beneficial Ownership Information (BOI) Report under the insurance company exemption to the Corporate Transparency Act (CTA). Likewise, companies that are owned by...more

Latham & Watkins LLP

WisdomTree Granted New York Limited Purpose Trust Company Charter

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As federal regulation remains patchy, firms may want to consider a New York state charter as a potential avenue to expand digital asset offerings in a compliant manner. On March 22, 2024, WisdomTree, Inc., a global asset...more

Akin Gump Strauss Hauer & Feld LLP

Update (2): The NY LLC Transparency Act and Corporate Transparency Act’s Impact on Private Fund Managers

In the weeks since publishing our original alert, FinCEN released several frequently asked questions (FAQs) on the application of the Corporate Transparency Act (CTA). Private fund managers are likely to find two of these...more

Dorsey & Whitney LLP

The Corporate Transparency Act: Are You Ready?

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On January 1, 2024, new direct reporting requirements to the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of the Treasury, became effective – known as the Corporate Transparency...more

Vinson & Elkins LLP

The Corporate Transparency Act - Subsidiary Exemption

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The Corporate Transparency Act (the “CTA”), a new federal law, went into effect on January 1, 2024 (see our update and summary here). In the weeks since, the Financial Crimes Enforcement Network (“FinCEN”) has continued to...more

BCLP

Navigating the Corporate Transparency Act Maze

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With the Corporate Transparency Act (CTA) now in effect, it is crucial for privately held mid-sized and large companies to look into and re-examine their corporate structures to ensure compliance with the new law. While the...more

Holland & Knight LLP

The Corporate Transparency Act: FinCEN Clarifies the Subsidiary Rule Exemption

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The Corporate Transparency Act (CTA) entered into force on Jan. 1, 2024. Under the beneficial ownership information reporting rule of the CTA, certain entities – such as corporations, limited liability companies and other...more

Akin Gump Strauss Hauer & Feld LLP

New Guidance on the Subsidiary Exemption Under the CTA’s Beneficial Ownership Information Reporting Rule

In the two weeks since the Corporate Transparency Act (CTA) went into effect (see our alert here), the Financial Crimes Enforcement Network (FinCEN) has published several Frequently Asked Questions (FAQs) clarifying the new...more

Willcox & Savage

Out of Scope - Exemptions from the Corporate Transparency Act

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The second installment in a multi-part series looking at the new Corporate Transparency Act discusses what is likely to be the first question that many companies have whenever a new law is passed – are we exempt? ...more

Goodwin

Luxembourg Administrative Court Decision: Parent-Subsidiary Exemption and Account 115 Contributions

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On March 31, 2022, the Luxembourg Administrative Court of Appeal ruled that, in order to determine the minimum acquisition value of a participation for the purposes of the Luxembourg parent-subsidiary exemption, the...more

Miles & Stockbridge P.C.

Collection Agency Licensing and Exemptions

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With the new collection agency rule of the Consumer Financial Protection Bureau (“CFPB”) having taken effect on November 30, 2021, we thought we could help round out your understanding of the collection agency laws by...more

Morrison & Foerster LLP

Narrowing of Licensing Exemption Under California Finance Lenders Law for Consumer Lenders and Brokers

The California Department of Business Oversight (the “CDBO”) has issued a new regulation that will eliminate a statutory licensing exemption under the California Finance Lenders Law (the “CFLL”) for nonbank operating...more

Katten Muchin Rosenman LLP

CFTC Proposes Revisions to Pending Aggregation Rules

The Commodity Futures Trading Commission (CFTC) has voted to seek public comment on revisions to its proposed rules requiring the aggregation of certain accounts for purposes of the CFTC's speculative position limits. If...more

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