STEP USA: The Corporate Transparency Act is coming. Are you ready?


  • Alan Winston Granwell TEP, Of Counsel, Holland & Knight LLP, Washington, DC


  • Megan R. Worrell TEP, Managing Director & Senior Wealth Advisor, J.P. Morgan Private Bank, New York, NY
  • Bruce Zagaris TEP, Partner, Berliner, Corcoran & Rowe LLP, Washington DC

Featuring an introduction from Tony Pitcher TEP, worldwide STEP Chair

Program Description:

The Corporate Transparency Act (CTA) is imminent, coming into force on January 1, 2024. It will impact over 32 million entities formed prior to 2024 and about 5 million entities per year for entities formed thereafter.

The CTA will require in-scope entities to report (i) identifying information about themselves, (ii) the individuals who directly or indirectly own or control the entity, and, (iii) for entities formed on or after the effective date (1/1/2024), the individual(s) - company applicants - who helped form/file entity documentation.

Equally significant for due diligence and compliance purposes, the CTA will require consideration of the content of organizational and transactional documentation in numerous areas, such as corporate, finance, banking, real estate, private wealth, tax and privacy.

Do not overlook that the CTA implicates domestic entities as well as foreign entities registered to do business in a state, irrespective of whether the beneficial owners are US or foreign individuals.

There is much to consider. So, are you ready for the CTA?

Topics covered:

  • How to comply with the CTA’s reporting requirements -a detailed work stream will be provided for existing and newly-formed Domestic Reporting Companies and Foreign Reporting Companies
  • How the content of organizational, transactional documents and other agreements/documents may need to be modified to deal with the CTA.
  • An overview of the detailed requirements of several of the more important exemptions to reporting and consideration of whether certain entities may be restructured to come within an exemption
  • A deep dive into how common-law trusts intersect with the CTA’s beneficial ownership information requirements
  • The impact of privacy limitations on beneficial ownership information reporting
  • Whether a foreign country can obtain access to beneficial ownership information.