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The Supreme Court of the United States stayed a nationwide injunction on January 23, 2025 in McHenry v. Texas Top Cop Shop, Inc. that would allow enforcement of the Beneficial Ownership Information (“BOI”) reporting requirements under the Corporate Transparency Act. However, FinCEN acknowledged on January 24, 2025 that the nationwide injunction from a different Eastern District of Texas case, Smith v. U.S. Department of the Treasury, remains in effect. As a result of the Smith case, BOI reports are still not required to be filed. Oral arguments in the Texas Top Cop Shop case are currently scheduled for March 25, 2025 before the United States Fifth Circuit Court of Appeal. Oral arguments have not been scheduled for the Smith case. We will provide further updates about the status of the BOI reporting deadline as they become available.

For further questions regarding the update, contact Liskow attorneys Leon Rittenberg III, Julie Chauvin, Marilyn Maloney, Caroline Lafourcade or Kevin Naccari, Jr. and visit our Tax Practice page.

Disclaimer: This Blog/Web Site is made available by the law firm of Liskow & Lewis, APLC (“Liskow & Lewis”) and the individual Liskow & Lewis lawyers posting to this site for educational purposes and to give you general information and a general understanding of the law only, not to provide specific legal advice as to an identified problem or issue. By using this blog site you understand and acknowledge that there is no attorney-client relationship formed between you and Liskow & Lewis and/or the individual Liskow & Lewis lawyers posting to this site by virtue of your using this site. The Blog/Web Site should not be used as a substitute for legal advice from a licensed professional attorney in your state regarding a particular matter.

Privacy Policy: By subscribing to Liskow & Lewisʼ E-Communications, you will receive articles and blogs with insight and analysis of legal issues that may impact your industry. Communications include firm news, insights, and events. To receive information from Liskow & Lewis, your information will be kept in a secured contact database. If at any time you would like to unsubscribe, please use the SafeUnsubscribe® link located at the bottom of every email that you receive.

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On July 24, 2024, FinCEN updated its Corporate Transparency Act FAQ section to confirm that disregarded entities may use their parent’s Employer Identification Number when filing Beneficial Ownership Reports. “If the disregarded entity does not have an EIN, it is not required to obtain one to meet its BOI reporting requirements so long as it can instead provide another type of TIN[.]” FinCEN Beneficial Ownership Information Frequently Asked Questions F.13.

For further questions regarding the update, please contact Liskow attorneys Leon Rittenberg III and Kevin Naccari, Jr. and visit our Corporate Transparency Act Resource Page.

Disclaimer: This Blog/Web Site is made available by the law firm of Liskow & Lewis, APLC (“Liskow & Lewis”) and the individual Liskow & Lewis lawyers posting to this site for educational purposes and to give you general information and a general understanding of the law only, not to provide specific legal advice as to an identified problem or issue. By using this blog site you understand and acknowledge that there is no attorney-client relationship formed between you and Liskow & Lewis and/or the individual Liskow & Lewis lawyers posting to this site by virtue of your using this site. The Blog/Web Site should not be used as a substitute for legal advice from a licensed professional attorney in your state regarding a particular matter.

Privacy Policy: By subscribing to Liskow & Lewisʼ E-Communications, you will receive articles and blogs with insight and analysis of legal issues that may impact your industry. Communications include firm news, insights, and events. To receive information from Liskow & Lewis, your information will be kept in a secured contact database. If at any time you would like to unsubscribe, please use the SafeUnsubscribe® link located at the bottom of every email that you receive.

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Another judge with the Eastern District of Texas enjoined enforcement of the Beneficial Ownership Information reporting requirements on Wednesday January 8, 2025. In Smith v. Dep’t of the Treasury, E.D. Tex., No. 6:24-cv-00336, 1/8/25, the court found that the “breadth” of the Corporate Transparency Act “expands federal power beyond constitutional limits.” Because a company formed under state law “is not a channel or instrumentality of commerce,” the court ruled that enforcement of the Act’s reporting requirements would exceed the authority granted to Congress under the Commerce Clause of the Constitution of the United States. The injunction in Smith only applies to the plaintiffs and their related entities. This comes as the Fifth Circuit Court of Appeals has sustained a nationwide injunction against the enforcement requirements while appeals are pending in Texas Top Cop Shop, Inc. v. Garland. The United States Treasury Department has submitted an emergency appeal to the Supreme Court of the United States in that case. We will provide any additional updates that may become available.

For further questions regarding the update, contact Liskow attorneys Leon Rittenberg IIIJulie ChauvinMarilyn MaloneyCaroline Lafourcade or Kevin Naccari, Jr. and visit our Tax Practice page.

Disclaimer: This Blog/Web Site is made available by the law firm of Liskow & Lewis, APLC (“Liskow & Lewis”) and the individual Liskow & Lewis lawyers posting to this site for educational purposes and to give you general information and a general understanding of the law only, not to provide specific legal advice as to an identified problem or issue. By using this blog site you understand and acknowledge that there is no attorney-client relationship formed between you and Liskow & Lewis and/or the individual Liskow & Lewis lawyers posting to this site by virtue of your using this site. The Blog/Web Site should not be used as a substitute for legal advice from a licensed professional attorney in your state regarding a particular matter.

Privacy Policy: By subscribing to Liskow & Lewisʼ E-Communications, you will receive articles and blogs with insight and analysis of legal issues that may impact your industry. Communications include firm news, insights, and events. To receive information from Liskow & Lewis, your information will be kept in a secured contact database. If at any time you would like to unsubscribe, please use the SafeUnsubscribe® link located at the bottom of every email that you receive.

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The Department of Justice won’t give up. Today, the Department of Justice filed an emergency writ asking the Supreme Court to suspend the nationwide preliminary injunction holding the Corporate Transparency Act (“CTA”) unconstitutional and to allow enforcement of the act and its Beneficial Ownership Information filings until the final resolution of the case. This request does not change the present status that CTA enforcement is temporarily suspended but indicates that the government will not quit in its efforts to implement the enforce the law.

More to come.

Disclaimer: This Blog/Web Site is made available by the law firm of Liskow & Lewis, APLC (“Liskow & Lewis”) and the individual Liskow & Lewis lawyers posting to this site for educational purposes and to give you general information and a general understanding of the law only, not to provide specific legal advice as to an identified problem or issue. By using this blog site you understand and acknowledge that there is no attorney-client relationship formed between you and Liskow & Lewis and/or the individual Liskow & Lewis lawyers posting to this site by virtue of your using this site. The Blog/Web Site should not be used as a substitute for legal advice from a licensed professional attorney in your state regarding a particular matter.

Privacy Policy: By subscribing to Liskow & Lewisʼ E-Communications, you will receive articles and blogs with insight and analysis of legal issues that may impact your industry. Communications include firm news, insights, and events. To receive information from Liskow & Lewis, your information will be kept in a secured contact database. If at any time you would like to unsubscribe, please use the SafeUnsubscribe® link located at the bottom of every email that you receive.

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Just in time for Christmas, the U.S. Fifth Circuit Court of Appeals lifted the nationwide injunction on enforcement of the Beneficial Ownership Information Report (“BOI Report”) filing requirements under the Corporate Transparency Act. This presumably means that BOI Reports will be due before January 1, 2025. We will continue to monitor FinCEN in hopes that a short extension will be granted. We will provide any updates that may become available.

For further questions regarding the update, contact Liskow attorneys Leon Rittenberg IIIJulie ChauvinMarilyn MaloneyCaroline Lafourcade or Kevin Naccari, Jr. and visit our Tax Practice page.

Disclaimer: This Blog/Web Site is made available by the law firm of Liskow & Lewis, APLC (“Liskow & Lewis”) and the individual Liskow & Lewis lawyers posting to this site for educational purposes and to give you general information and a general understanding of the law only, not to provide specific legal advice as to an identified problem or issue. By using this blog site you understand and acknowledge that there is no attorney-client relationship formed between you and Liskow & Lewis and/or the individual Liskow & Lewis lawyers posting to this site by virtue of your using this site. The Blog/Web Site should not be used as a substitute for legal advice from a licensed professional attorney in your state regarding a particular matter.

Privacy Policy: By subscribing to Liskow & Lewisʼ E-Communications, you will receive articles and blogs with insight and analysis of legal issues that may impact your industry. Communications include firm news, insights, and events. To receive information from Liskow & Lewis, your information will be kept in a secured contact database. If at any time you would like to unsubscribe, please use the SafeUnsubscribe® link located at the bottom of every email that you receive.

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The Financial Crimes Enforcement Network (FinCEN) finalized a rule on August 28, 2024 that creates new reporting requirements for certain transfers of residential real estate. Under the new rule, transfers of residential real estate not already subject to the Anti-Money Laundering and Countering the Financing of Terrorism regulatory regime will be required to submit a Real Estate Report. The new regulations take effect on December 1, 2025. The Real Estate Report must be filed electronically with FinCEN by the final day of the month following the closing date, or thirty (30) days, whichever is longer. The person or entity required to report the transaction shall be determined based on a cascading tier of professionals involved in the transfer.

Residential real property encompasses: (1) any property in the United States with a structure intended for occupancy by one to four families; (2) vacant land in the U.S. designated for a structure meant for one to four families; or (3) shares in a cooperative housing corporation in the U.S. The proposed rule covers single-family homes, townhomes, condominiums, cooperatives, and small apartment buildings with up to four families.

The reporting requirements apply unless the transferee is an individual or an exempt entity or trust. For individuals, the property must be titled in the owner’s name to be exempt from reporting. Entities exempt from reporting include those already subject to significant data collection, such as securities issuers required to register with the SEC, depository institutions, banks, credit unions, insurance companies, subsidiaries of exempt entities, broker/dealers, and public utilities. Non-profit entities are not exempt from these requirements.

The proposed rule mandates reporting for all property transfers, regardless of value or price. This includes gratuitous transfers like gifts and transfers to trusts. However, transfers involving financed properties where the real estate secures a loan are exempt if the lending institution maintains an Anti-Money Laundering program and files Suspicious Activity Reports. Also exempt are low-risk transfers related to easements, as well as those resulting from death, divorce, or bankruptcy.

The final rule did add an additional exemption for certain estate planning transfers. Transfers of residential real property to a trust will not be reportable if: (1) the transfer is for no consideration; (2) the transferor of the property is an individual (either alone or with the individual’s spouse); and (3) the settlor or grantor of the trust is that same transferor individual, that individual’s spouse, or both of them. But FinCEN rejected comments suggesting that transfers to legal entities, such as a contribution to capital made by a partner or member, should be exempt. “FinCEN intended to scope this exception in a manner that was responsive to comments but that would not create an overly broad exception that would be open to significant abuse.”

The rule establishes a tiered system for reporting obligations. In the first tier, real estate professionals who provide settlement services must compile and file the report, typically the person listed as the closing or settlement agent. If no such agent is involved, the second tier falls to the entity underwriting the owner’s title insurance policy. If no title insurance is underwritten, the third tier goes to the person disbursing the largest amount of funds related to the transfer. If none of the first three tiers are applicable, the fourth tier is assigned to the person preparing a title evaluation. Lastly, if none of the previous tiers apply, the fifth tier applies to the person preparing the deed.

The Real Estate Report will gather information about the beneficial owners of the transferee entity or trust, based on definitions from the Corporate Transparency Act. The report must include details of any individual who, directly or indirectly, has substantial control over the transferee entity or owns at least 25% of its ownership interests. For trusts, it must identify trustees, those with authority to manage trust assets, beneficiaries with exclusive rights to income and principal, grantors or settlors of revocable trusts, and beneficial owners of entities holding these positions. However, the rule does not require reporting of changes in beneficial ownership after the initial report.

The final rule adopts a reasonable reliance standard that allows reporting persons to reasonably rely on information provided by other persons. But the reasonable reliance standard only applies to information provided by the transferee or the transferee’s representative when the person providing the information certifies the accuracy of the information in writing when the reporting person is reporting beneficial ownership information of transferee entities or transferee trusts. Although commenters argued that the standard was too vague and that reporting persons should be able to submit incomplete reports when a party to the transfer declines to provide such information, FinCEN rejected these comments because the “reasonable reliance standard is consistent with that used by certain financial institutions subject to customer due diligence requirements[,]” and that “allowing for the submission of incomplete reports could make it easier for transferees to avoid reporting requirements while also making it difficult for FinCEN to ensure compliance with the rule.”

For further questions regarding the rule, please contact Liskow attorneys Leon Rittenberg III and Kevin Naccari, Jr. and visit our Real Estate practice page.

Disclaimer: This Blog/Web Site is made available by the law firm of Liskow & Lewis, APLC (“Liskow & Lewis”) and the individual Liskow & Lewis lawyers posting to this site for educational purposes and to give you general information and a general understanding of the law only, not to provide specific legal advice as to an identified problem or issue. By using this blog site you understand and acknowledge that there is no attorney-client relationship formed between you and Liskow & Lewis and/or the individual Liskow & Lewis lawyers posting to this site by virtue of your using this site. The Blog/Web Site should not be used as a substitute for legal advice from a licensed professional attorney in your state regarding a particular matter.

Privacy Policy: By subscribing to Liskow & Lewisʼ E-Communications, you will receive articles and blogs with insight and analysis of legal issues that may impact your industry. Communications include firm news, insights, and events. To receive information from Liskow & Lewis, your information will be kept in a secured contact database. If at any time you would like to unsubscribe, please use the SafeUnsubscribe® link located at the bottom of every email that you receive.

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After receiving complaints that disregarded entities required to file Beneficial Ownership Information (BOI) Reports could not do so using their parent’s Employer Identification Number (EIN), the Financial Crimes Enforcement Network (FinCEN) has corrected the issue. Since Treasury Regulation Section 301.6109-1(h)(2)(i) took effect in 1997, the Internal Revenue Service (IRS) has permitted disregard entities, including single member limited liability companies to use the Employee Identification Number (EIN) of its owner (unless the disregarded entity has employees). Unfortunately, and without any regulatory authority, the Financial Crimes Enforcement Network (FinCEN) initially would not permit disregarded entities to use their owner’s EIN for purposes of beneficial ownership reporting. 

This regulatory mismatch created filing complications because the FinCEN online Beneficial Ownership Information reports would only allow one filing per EIN. As a result, a disregarded entity using its parent’s EIN was not able to file its BOI report without first applying for an EIN from IRS. Disregarded entities meeting the Corporate Transparency Act’s “Reporting Company” definition were, in effect, no longer permitted to use their owner’s EIN. But on June 27, 2024, FinCEN corrected the error, allowing disregarded entities to use the parent’s EIN without receiving an error. Going forward, reporting companies may use the same EIN for multiple entities.

For further questions regarding the correction, please contact Liskow attorneys Leon Rittenberg III and Kevin Naccari, Jr. and visit our Corporate Transparency Act Resource page.

Disclaimer: This Blog/Web Site is made available by the law firm of Liskow & Lewis, APLC (“Liskow & Lewis”) and the individual Liskow & Lewis lawyers posting to this site for educational purposes and to give you general information and a general understanding of the law only, not to provide specific legal advice as to an identified problem or issue. By using this blog site you understand and acknowledge that there is no attorney-client relationship formed between you and Liskow & Lewis and/or the individual Liskow & Lewis lawyers posting to this site by virtue of your using this site. The Blog/Web Site should not be used as a substitute for legal advice from a licensed professional attorney in your state regarding a particular matter.

Privacy Policy: By subscribing to Liskow & Lewisʼ E-Communications, you will receive articles and blogs with insight and analysis of legal issues that may impact your industry. Communications include firm news, insights, and events. To receive information from Liskow & Lewis, your information will be kept in a secured contact database. If at any time you would like to unsubscribe, please use the SafeUnsubscribe® link located at the bottom of every email that you receive.

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Since Treasury Regulation Section 301.6109-1(h)(2)(i) took effect in 1997, the Internal Revenue Service (IRS) has permitted disregard entities, including single member limited liability companies, to use the Employee Identification Number (EIN) of its owner (unless the disregarded entity has employees). Unfortunately, and without any regulatory authority, the Financial Crimes Enforcement Network (FinCEN) is not permitting disregarded entities to use their owner’s EIN for purposes of beneficial ownership reporting.  Certain banks also now are requiring that, to open a bank account, a single member limited liability company obtain an EIN.  These requirements are in direct conflict with the Treasury Regulations.  Under 26 U.S.C.A. § 6109, Congress delegated the authority to determine when and to whom EIN’s must be issued to the IRS.

This regulatory mismatch has created filing complications because the FinCEN online Beneficial Ownership Information (BOI) reports currently only allow one filing per EIN. As a result, a disregarded entity using its parent’s EIN will not be able to file its BOI report without first applying for an EIN from IRS.

This likely means that disregarded entities meeting the Corporate Transparency Act’s “Reporting Company” definition will, in effect, no longer be permitted to use their owner’s EIN going forward unless the Treasury Department corrects the error in conflict with Treasury Regulations. FinCEN has not yet addressed this issue in any of the published guidance, including the Frequently Asked Questions section of its Corporate Transparency Act website.

For further questions regarding this update, contact Liskow attorneys Leon Rittenberg III, Marilyn Maloney, Julie Chauvin and Kevin Naccari and visit our Corporate Transparency Act Resource Page.

Disclaimer: This Blog/Web Site is made available by the law firm of Liskow & Lewis, APLC (“Liskow & Lewis”) and the individual Liskow & Lewis lawyers posting to this site for educational purposes and to give you general information and a general understanding of the law only, not to provide specific legal advice as to an identified problem or issue. By using this blog site you understand and acknowledge that there is no attorney-client relationship formed between you and Liskow & Lewis and/or the individual Liskow & Lewis lawyers posting to this site by virtue of your using this site. The Blog/Web Site should not be used as a substitute for legal advice from a licensed professional attorney in your state regarding a particular matter.

Privacy Policy: By subscribing to Liskow & Lewis’ E-Communications, you will receive articles and blogs with insight and analysis of legal issues that may impact your industry. Communications include firm news, insights, and events. To receive information from Liskow & Lewis, your information will be kept in a secured contact database. If at any time you would like to unsubscribe, please use the SafeUnsubscribe® link located at the bottom of every email that you receive.

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On February 16, 2024, the Treasury Department published a proposed regulation relating to new reporting requirements for certain transfers of residential real estate consistent with its rulemaking authority under the Bank Secrecy Act. The rule would require the filing of a Real Estate Report with the Financial Crimes Enforcement Network (FinCEN) after the transfer of residential real estate. Reportable transfers include any transfer, including many gratuitous transactions, of residential real property to an entity or trust not already subject to the Anti-Money Laundering and Countering the Financing of Terrorism regulatory regime. The Real Estate Report will need to be filed electronically on the FinCEN website no more than thirty (30) days after closing.

Residential Real Property

Residential real property includes: (1) any real property located in the United States with a structure designed to be occupied by one to four families, (2) vacant land in the United States zoned for a structure designed for one to four families, or (3) shares in a cooperative housing corporation in the United States. This applies even if there is a commercial component to the property, such as a residential unit located above a commercial enterprise. The proposed rule intends to include single-family homes, townhomes, condominiums, cooperatives, and small apartment buildings designed for four or fewer families. Property within the United States would include property within any of the fifty states, the District of Columbia, the Indian lands as defined in the Indian Gaming Regulatory Act, and any territory or possession of the United States. The broad geographic scope intends to discourage money laundering schemes in exempt territories.

Covered Transferees and Exemptions

The reporting requirements apply when the transferee is not an individual or an exempt entity or trust. For an individual, the real property must be titled in the owner’s name to be exempt from the reporting requirements. Certain entities may be exempt because they are already subject to sufficient data collection, such as securities reporting issuers, including companies that must register securities with the Securities and Exchange Commission. Other examples of exempt entities include depository institution holding companies, banks, credit unions, insurance companies, subsidiaries of exempt entities, broker/dealers in securities, and public utilities. Non-profit entities, however, will not be exempt from the reporting requirements.

Reportable Transfers

The proposed rule makes transfers reportable regardless of value or purchase price. Accordingly, gratuitous transfers like gifts and transfers to trusts would generally be included. The rule does make exceptions for certain low-risk transfers or transfers already subject to sufficient scrutiny. Financed transfers where the real property serves as security for the loan and the financial institution making the loan has an obligation to maintain an Anti-Money Laundering program and file Suspicious Activity Reports would be exempt from the filing requirements. Low-risk transfers resulting in the grant, transfer, or revocation of an easement also enjoy an exemption. Additionally, transfers resulting from death, divorce, or bankruptcy are exempt. Finally, transfers that do not involve a reporting person, discussed below, enjoy an exemption.

Cascading Tiers

The proposed rule creates a cascading tier of reporting persons who will be subject to the reporting requirements. In the first tier, real estate professionals providing certain settlement services in the settlement process must compile the necessary information and file the report. Specifically, the person listed as the closing or settlement agent on a settlement or closing statement usually will fall into this tier. If no one executes the specific settlement functions in the first tier, the second reporting tier falls to the person that underwrites an owner’s title insurance policy of the transferee. If there is no person underwriting a title insurance policy, the third reporting tier falls to the person that disburses the greatest amount of funds in connection with the transfer. If no person meets the first three criteria, the fourth reporting tier falls to the person that prepares an evaluation of the title status. Finally, when no person in the first four tiers participates in the transaction, the fifth reporting tier falls to the person who prepares the deed.

Beneficial Owners

The proposed Real Estate Report will collect information about the beneficial owners of the transferee entity or transferee trust. The definitions of beneficial ownership largely follow the definitions in the Corporate Transparency Act. Real Estate Reports must include information for any individual who, directly or indirectly, either exercises substantial control over the transferee entity or owns or controls at least twenty-five percent (25%) of the ownership interests of the transferee entity. Additionally, the Report must include information on beneficial owners of transferee trusts including anyone who is a trustee, otherwise has authority to dispose of trust assets, is a beneficiary who is the sole permissible recipient of income and principal with a right to demand distribution of substantially all of the assets of the trust, is a grantor or settlor of a revocable trust, or is the beneficial owner of a legal entity or trusts holding one of these positions. However, the rule would not require reporting of subsequent changes in the beneficial ownership of the transferee entity or trust.

For further questions regarding this topic, contact Liskow attorneys Kevin Naccari, Jr. and Leon Rittenberg, III.

Disclaimer: This Blog/Web Site is made available by the law firm of Liskow & Lewis, APLC (“Liskow & Lewis”) and the individual Liskow & Lewis lawyers posting to this site for educational purposes and to give you general information and a general understanding of the law only, not to provide specific legal advice as to an identified problem or issue. By using this blog site you understand and acknowledge that there is no attorney-client relationship formed between you and Liskow & Lewis and/or the individual Liskow & Lewis lawyers posting to this site by virtue of your using this site. The Blog/Web Site should not be used as a substitute for legal advice from a licensed professional attorney in your state regarding a particular matter.

Privacy Policy: By subscribing to Liskow & Lewis’ E-Communications, you will receive articles and blogs with insight and analysis of legal issues that may impact your industry. Communications include firm news, insights, and events. To receive information from Liskow & Lewis, your information will be kept in a secured contact database. If at any time you would like to unsubscribe, please use the SafeUnsubscribe® link located at the bottom of every email that you receive.

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Since 2016, the Financial Crimes Network of the Treasury Department (“FinCEN”) has issued orders requiring title insurance companies to report certain non-financed residential real estate transactions to entities and trusts above a certain price threshold. These “Residential Real Estate Geographic Targeting Orders” or “GTOs” are limited to certain locations in the United States.  They have been expanded since 2016 and currently address certain metropolitan areas in California, Florida, Hawaii, Illinois, Massachusetts, Nevada, New York, Texas, and Washington.  The reason for the reporting requirements is the determination by FinCEN that cash transactions of residential real estate are a popular means of laundering illegal moneys. 

On Wednesday, FinCEN published notice of proposed rule making for a nationwide order that would require attorneys, title companies, brokers, and other real estate professionals (“Reporting Persons”) to report certain sales and donations to entities and trusts without regard to size of the purchase price.  Like the GTOs, this regulation would not address transactions that are financed by financial institutions that are required to have established anti-money laundering procedures and that are required to file suspicious activity reports.  However, loans by private lenders that are not subject to those regulatory requirements would not exempt the Reporting Person from the obligation to report transactions.

Notably, the proposed rule would require filing a “Real Estate Report” on a form that has not yet been published. It would require submission of beneficial ownership information for the legal entity or trust, not unlike the information required under the Corporate Transparency Act.  The rule would include a wide list of exceptions for transferee entities, including large, regulated entities.  Certain types of transfers, including those that result from the death of a property owner, a divorce, or a transfer to a bankruptcy estate, would also be excluded.  Notably not excluded are other types of common estate planning transfers, such as creation of family management trusts and transfers of real property to those trusts.

The proposed rules, as applied to the common estate planning transactions, will create a substantial burden on practitioners and their clients.

Links to the proposed rule, as well as explanatory details, are listed below.  Comments to the rule may be made for 60 days after the rule is published in the Federal Register.

News Release

Fact Sheet

Notice of Proposed Rulemaking

Contact Liskow attorneys Marilyn Maloney and Leon Rittenberg III for further questions regarding this topic and visit our Real Estate and Tax practice pages.

Disclaimer: This Blog/Web Site is made available by the law firm of Liskow & Lewis, APLC (“Liskow & Lewis”) and the individual Liskow & Lewis lawyers posting to this site for educational purposes and to give you general information and a general understanding of the law only, not to provide specific legal advice as to an identified problem or issue. By using this blog site you understand and acknowledge that there is no attorney-client relationship formed between you and Liskow & Lewis and/or the individual Liskow & Lewis lawyers posting to this site by virtue of your using this site. The Blog/Web Site should not be used as a substitute for legal advice from a licensed professional attorney in your state regarding a particular matter.

Privacy Policy: By subscribing to Liskow & Lewis’ E-Communications, you will receive articles and blogs with insight and analysis of legal issues that may impact your industry. Communications include firm news, insights, and events. To receive information from Liskow & Lewis, your information will be kept in a secured contact database. If at any time you would like to unsubscribe, please use the SafeUnsubscribe® link located at the bottom of every email that you receive.