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Congress Enacts the Corporate Transparency Act Requiring Certain Entities to Disclose their Owners

On January 1, 2021, Congress enacted the National Defense Authorization Act (the NDAA”). One portion of the NDAA includes the Corporate Transparency Act (the “CTA”), which is described as the most comprehensive anti-money laundering legislation passed in the United States and which regulates the use of anonymous entities for money laundering, tax evasion, and financing terrorism.  The CTA requires certain entities, including limited liability companies, corporations, and “similar entities,” to disclose their individual owners and their “beneficial owners”, meaning those who own or control at least 25% of the entity.  The legislation is aimed at preventing these “shell companies” from hiding illegal activity.

The statute states that the CTA only applies to entities that are created by filing a document with a secretary of state or a similar office, or are formed under the laws of a foreign country, but are registered to do business in the United States through

IRS extends more tax deadlines; EO operations affected during COVID-19 and more

Last month, the IRS announced that certain taxpayers generally have until July 15, 2020, to file and pay federal income taxes originally due on April 15. The IRS has extended this relief to additional returns, tax payments and other actions. As a result, the extensions generally now apply to all taxpayers that have a filing or payment deadline falling on or after April 1, 2020, and before July 15, 2020. The extensions apply to many forms and tax payments made by tax-exempt organizations, including:

  • Form 990-series annual information returns or notices (Forms 990, 990-EZ, 990-PF, 990-BL, 990-N (e-postcard))
  • Forms 8871 and 8872
  • Form 5227
  • Form 990-T
  • Form 1120-POL
  • Form 4720
  • Form 8976

See Notice 2020-23 and Rev. Proc. 2018-58 for more information, including a complete list of affected forms, tax payments and other time-sensitive actions.

IRS operations during COVID-19: mission-critical functions continue

In response to the coronavirus (COVID-19) crisis, the

BCLP Partner Stephanie Moll in November STEP Journal

December 19, 2019

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Stephanie Moll was quoted in the November issue of the STEP Journal article, “All to Play For.” This article discusses potential changes in trust and estate law and taxation as the United States and Canada move into an election year. In particular, Moll discusses current issues faced by US taxpayers with foreign bank accounts as a result of certain reporting requirements. The complete article can be found here.

Bryan Cave Shortlisted For 2016 Magic Circle Awards

Bryan Cave has made the shortlist for the prestigious Magic Circle Awards for 2016 under the category of “International Law Firm of the Year – USA”.

The Magic Circle Awards are held annually each Spring to recognize the best advisors in the financial sector on a global scale.

Congratulations to London Private Client Services Partner, Dyke Arboneaux

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Private Client Services Partner in London, Dyke Arboneaux, has been selected as both a speaker at the STEP Global Congress and as a judge for the 2016-2017 STEP Awards.

Dyke advises individuals, families and financial institutions on international estate planning and U.S. tax matters, with a particular emphasis in planning for clients who are exposed to both the U.S. and U.K. tax systems.

Congratulations!

Tax Benefits for Many U.K. Non-Doms to Be Reduced

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Last month, the UK government announced sweeping changes to the taxation of “resident non doms,” a classification of individuals who receive favorable tax treatment from the UK government.

The UK tax obligations of an individual depend in large part on the individual’s “domicile” under generally applicable English common law principles. (Unlike the US tax system, the citizenship of an individual is irrelevant under the UK tax system.) The UK income tax and capital gains tax systems (which operate as two separate regimes of tax) take into account the “residence” status of an individual, as well. The residence rules were massively overhauled with effect from 6th April 2013. Note that a UK tax year runs from April 6 to April 5 of the following years.

Because of quirks in the English

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