The Corporate Transparency Act (CTA) became law on 1 January 2021. This article considers aspects of the new act, such as the broad definition of 'beneficial owner' when applied to trusts, privacy concerns and further compliance responsibilities that may be of interest in the context of family succession planning structures that include entities established under the laws of a US state.
The Corporate Transparency Act (CTA) recently became law. Once implementation regulations are issued, the CTA will require certain new and existing US companies to disclose information about their beneficial owners. There are both civil and criminal penalties for violations of CTA requirements. Given that family succession planning structures may include entities established under the laws of a US state, advisers to international families should familiarise themselves with this new disclosure requirement.
The Section 962 election has become one of the most common planning tools for tax professionals over the past couple of years. However, it is important to keep in mind that each situation is different. With variables ranging from projected actual future distributions to local country tax rates, it is always important to consider making a Section 962 election among other planning alternatives, not as the only planning alternative.