On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule to the U.S. Corporate Transparency Act (“CTA”) that eliminates beneficial ownership information (“BOI”) reporting requirements for domestic entities and U.S. persons. The immediate result of the interim final rule is that no U.S. entities are
Martine Seiden Agatston
Martine Seiden Agatston is a senior counsel in the Tax Department in the Los Angeles office. Her practice focuses on general tax matters, including domestic and international transactions. Representative matters have included U.S. and cross-border financings, debt and equity capital markets transactions, complex mergers and acquisitions and corporate restructurings, as well as representation before the tax authorities. She also has acted for REITs, RICs (including BDCs) and other regulated investment entities on transactional matters.
CTA – The Large Operating Company Exemption – Not Everybody Can Be A “Big BOI”
In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) to propose rules requiring certain types of entities to file…