Corporate Transparency Act – Initial Information



Rödl & Partner Tax Matters Volume 2022-6, published December 14 , 2022

In 2021, Congress passed the Corporate Transparency Act requiring disclosure of the ultimate beneficial owners of U.S. and foreign corporations to FinCEN starting in 2024. Final Regulations were released on September 29, 2022. Below please find key takeaways from recently released regulations. We will provide more information as it becomes available but certain taxpayers should anticipate new compliance requirements in the future.


Reporting starts January 1, 2024. Companies created or registered prior to that date have one year to register and file their annual report. Companies created or registered after that date have to register and to file their initial report.


Reporting will be required for both U.S. and foreign entities (e.g., corporations, LLCs, partnerships) which are formed or registered to do business under the law of a state or Indian tribe. Trusts which do not register under state law should be excluded. FinCEN expects over 30 million filings in the initial year and 5 million a year thereafter.


Reporting entities must disclose information about beneficial owners, defined to include both individuals who own directly or indirectly 25% of the entity and individuals who exercise substantial control over the reporting entity (i.e., make important decisions on behalf of the entity, including senior officers).


Required disclosure for beneficial owners will include name, birth date, address and a unique identifying number with documentation including the image of such individual (e.g., passport, driver's license). FinCEN can then issue a FinCEN identifying number for future filings.


Changes in beneficial ownership must be reported within 30 days.


More regulations and guidance are expected in the next year, including limitations on who has access to the data. We will keep you updated as more information becomes available.


If you have questions, please contact your local Rödl & Partner representative. 

This publication contains general information and is not intended to be comprehensive or to provide legal, tax or other professional advice or services. This publication is not a substitute for such professional advice or services, and it should not be acted on or relied upon or used as a basis for any decision or action that may affect you or your business. Consult your advisor.

We have made reasonable efforts to ensure the accuracy of the information contained in this publication, however this cannot be guaranteed. Neither Rödl Langford de Kock LP nor any of its subsidiaries nor any affiliate thereof or other related entity shall have any liability to any person or entity which relies on the information contained in this publication, including incidental or consequential damages arising from errors or omissions. Any such reliance is solely at user's risk.

Any tax and/or accounting advice contained herein is based on our understanding of the facts, assumptions we have been asked to make, and on the tax laws and/or accounting principles in effect as of the date of this advice. No assurance is given that the conclusions would be the same if the facts or assumptions change, or are not as we understand them, or that the tax laws and/or accounting principles will not change subsequent to the issuance of these conclusions. In addition, we do not undertake any continuing obligation to advise on future changes in the tax laws and/or accounting principles, or of the impact on the conclusions herein.

No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Rödl Langford de Kock LP.

Copyright © December 2022 Rödl Langford de Kock LP
All rights reserved.


Contact Person Picture

Elisa Fay


Partner-in-Charge Rödl National Tax

+1 404 525 2600

Send inquiry


Italian Speaking Contact

Contact Person Picture

Filiberto Calascibetta

CPA, Dottore Commercialista, Honorary Consul of Italy in Atlanta

Partner, Italian Speaking

+1 404 525 2600

Send inquiry


German Speaking Contact

Contact Person Picture

Matthias Amberg


Partner, German Speaking

+1 312 857 1950

Send inquiry


Deutschland Weltweit Search Menu