Corporate Transparency Act Update AGAIN! – Filing Requirements Suspended AGAIN – No Filing Required – For Now

This Client Alert further updates you of yesterday’s uncommon decision of the U.S. Court of Appeals for the Fifth Circuit, where the court reversed its recent decision (published three days ago) related to the reversal of nationwide injunction on the beneficial ownership interest (“BOI”) reporting requirements as set forth in the Corporate Transparency Act.  The effect of the published opinion three days ago is that BOI reporting was required by January 13, 2025.  The effect of yesterday’s opinion is that the BOI reporting requirement is once again suspended (i.e., there is no BOI reporting requirement, for now) … We encourage you to read this Client Alert.

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Corporate Transparency Act Update - Filing Requirements Active Again - New Filing Deadline – January 13, 2025

BREAKING NEWS: This Client Alert updates you of the recent decision of the U.S. Court of Appeals for the Fifth Circuit (published yesterday, December 23, 2024) overturning the injunction on the beneficial ownership interest (“BOI”) reporting requirements as set forth in the Corporate Transparency Act.   If you are required to file a BOI report and have not yet done so, you will have to do so now.

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The Who, What, When, Where and How of the CTA

The Corporate Transparency Act (the “CTA”), effective as of January 1, 2024, establishes significant, and potentially onerous, beneficial ownership reporting requirements on a broad range of entities.  The attached Client Alert aims to distill the reporting obligations, highlight some areas lacking clarity, and advise our clients to discuss their potential CTA reporting obligations with their various advisors.  

 For additional information, see the FinCen Beneficial Ownership FAQs

Planning for the 2026 Sunset of the Lifetime Gift & Estate Tax Exclusion

The Federal gift and estate exclusion amount in 2023 stands at $12.92 million per person.  A significant change is scheduled for January 1, 2026, when the gift and estate exclusion is set to be reduced by half.  The estate planning implications of this impending change are broad and much discussed in existing literature.  This Client Alert delves into the lesser-discussed implications of the upcoming change.

Proposed Changes to Income and Transfer Taxes – A Brief Summary of the Estate Planning Changes in the New $3.5 Trillion Infrastructure Proposal

In late August 2021, by a 220 – 212 party-line vote, the House of Representatives passed a $3.5 trillion
budget resolution,1 while also advancing the $1 trillion bipartisan infrastructure bill.

On September 13, 2021, House Ways & Means Committee Chairman Richard E. Neal (D-MA) released
the initial legislative text and a summary of the proposed “Build Back Better Act” (the “Proposal”). On
September 15, 2021, the Committee approved its sections of the Proposal that mostly addressed social issues and plans to pay for them with tax increases. The Proposal contains provisions that, presumably, seek to increase taxes on the higher income and high net worth taxpayers.

The focus of this Client Alert is on estate planning changes, which include increasing ordinary income
and capital gains tax rates for high income earners, lowering transfer tax exemptions, subjecting certain
irrevocable grantor trusts to the estate tax, and attempting to overhaul the “grantor trust” income tax rules.

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Gift, Estate and GST Exclusion Amounts for 2021

As 2021 begins, for now (although this may change, as described below) the current gift and estate tax exclusions, GST exemption amount, tax rates, and annual gift tax exclusion are as follows:

Federal

Gift and Estate Tax Exclusions

The gift and estate tax exclusion amount (also called the “applicable exclusion amount”) increased slightly from $11.58 million (in 2020) to $11.7 million (in 2021) per individual (or $23.4 million for a married couple).1 Estates of decedents survived by a spouse may still elect to pass any of the decedent’s unused applicable exclusion amount to the surviving spouse by an election made on a timely filed estate tax return for the decedent with a surviving spouse (also known as “portability”).

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