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In brief

On 8 December 2021, Treasury issued Notice of Proposed Rulemaking to allow the public to review and comment on proposed regulations (“Proposed Regulations“) to implement the beneficial ownership information reporting provisions of the Corporate Transparency Act (CTA). Passed on 1 January 2021, the CTA imposes on so-called “Reporting Companies” the obligation to report to Financial Crimes Enforcement Network (FinCEN) information regarding their “Beneficial Owners” and company “Applicants.” This Client Alert reviews the Proposed Regulations and is a companion to our January 2021 Client Alert that provided an overview of the CTA shortly after it was enacted and which can be found here: Client Alert – Updates on Beneficial Ownership Reporting in the United States.

The CTA itself does not sufficiently define various terms essential for its implementation. The Proposed Regulations are intended to provide clarification and guidance on the reporting obligations mandated by the CTA. The Proposed Regulations are essential for another reason as well, since the CTA provides that its beneficial ownership reporting requirements take effect”… on the effective date of the regulations prescribed by the Secretary of the Treasury.”

Below we summarize the Proposed Regulations and draw special attention to FinCEN’s clarification of issues of concern for high net worth individuals.

Click here to download the full alert.


Glenn G. Fox is a partner of Baker McKenzie's Wealth Management and Tax Practice Groups in New York and a member of the firm’s Global Tax Wealth Management Steering Committee. He is a domestic and international tax, estate planning, and tax-exempt (charitable) organizations lawyer with vast experience working with closely held businesses, families and charitable organizations from the US and overseas. Glenn is a member of the American College of Trust and Estate Counsel and of the Society of Trust and Estate Practitioners and has been recognized for fourteen consecutive years (2007-2020) as a "New York Super Lawyer" by the New York Times.


Lyubomir Georgiev has practiced law since 2003 in the United States and Switzerland. He has assisted banks, insurance companies, fiduciaries, family offices, asset managers, and high net worth individuals. Lyubomir participated in the negotiations of the special arrangements between the Government of the Principality of Liechtenstein and the UK on voluntary disclosure, tax compliance certification and tax information exchange. He heads the International Tax and Global Wealth Management practice in Zurich. Lyubomir has worked in Washington, DC and New York. Previously he was a member of the EMEA Wealth Management Steering Committee and Knowledge Management & Training head. Lyubomir is admitted to practice in Washington, DC, US Tax Court, England and Wales, and Switzerland as a foreign-qualified solicitor. He has been ranked in Chambers Global since 2012 as a foreign expert in practice areas such as UK tax and private clients, US private clients, and Liechtenstein tax and general business law.


Gregory Walsh is an attorney in the International Tax and Global Wealth Management practice groups and co-head of the FATCA/CRS practice at Baker McKenzie in Switzerland. In connection with tax and wealth management matters, he also has substantial experience advising clients in corporate and securities issues. Gregory focuses his practice on international tax planning and global wealth management matters. He advises financial institutions and private clients on trust and company structures, FATCA and CRS compliance, US withholding tax and Qualified Intermediary compliance, tax treaty issues, individual and corporate tax planning, financial institution tax compliance and tax regularization matters. He advises closely held businesses and wealth management enterprises in restructuring and compliance matters. He also serves as counsel to global executives in connection with cross-border and mobility planning and compliance. Gregory speaks regularly on financial institution tax and automatic exchange of information (AEOI) compliance issues and has presented at conferences in Europe and the Middle East. He has developed training and compliance materials for financial institutions in these areas and he has lectured at universities and for private educational providers on AEOI, US tax, international tax, and wealth management matters. In connection with international tax and wealth management matters, Gregory also advises clients in diverse corporate law issues including mergers and acquisitions, securities transactions and compliance, corporate governance and commercial transactions. As part of a cross-border practice, he regularly assists clients in interdisciplinary matters in both English and German.

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