Alert 01.06.26
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UPDATE (1/6): The status of the Federal Corporate Transparency Act (CTA) and other federal and state Beneficial Ownership Disclosure initiatives was in flux throughout 2025 and remains that way as a new year begins. Under the Trump administration, the Department of the Treasury, through FinCEN, has limited or postponed the effective date of actions taken during the Biden administration, and these actions remain subject to ongoing litigation and potential legislative or regulatory changes. Meanwhile, New York State’s beneficial ownership information disclosure requirements—the LLC Transparency Act, the first state action of this kind—has become effective, though with a more limited scope than initially intended. To understand the current state of play, review our latest alert.
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Members of the Pillsbury CTA task force have been tracking the CTA’s evolution since 2021, including the voluminous regulations it entails. The firm's lawyers are prepared to assist clients in dealing with the tricky and not always clear requirements of the CTA, and to support related legal needs.