Under the Corporate Transparency Act companies are generally required to report detailed information about their beneficial owners, commencing January 1, 2024. On November 7, 2023, The United States Treasury issued amendments to its regulations with respect to reporting for tiered entities where the lower tier entities have precisely the same owners. In this instance, in lieu of separately reporting details about the lower tier entity, the lower tier entity may report by providing a FinCEN Identifier (think known traveler number). Specifically, the amendment provides:
§ 1010.380 Reports of beneficial ownership information. (B) A reporting company may report another entity's FinCEN identifier and full legal name in lieu of the information required under paragraph (b)(1)(ii) of this section with respect to the beneficial owners of the reporting company only if: (1) The other entity has obtained a FinCEN identifier and provided that FinCEN identifier to the reporting company; (2) An individual is or may be a beneficial owner of the reporting company by virtue of an interest in the reporting company that the individual holds through an ownership interest in the other entity; and (3) The beneficial owners of the other entity and of the reporting company are the same individuals.
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