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Corporate Transparency Act for Foreign Reporting Companies: Filing Requirements, Utilizing FinCEN Identifiers

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, January 25, 2024

Recorded event now available

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This webinar will provide an in-depth look at how the new Corporate Transparency Act (CTA) applies to international taxpayers. Our panel of foreign tax professionals will review the latest requirements for divulging personal ownership information as it applies to foreign entities and individuals.


Beginning Jan. 1, 2024, small businesses, including certain "foreign reporting companies," are required to report beneficial ownership information (BOI) to the U.S. Department of Treasury's Financial Crimes Enforcement Network, better known as FinCEN. Foreign entities, already familiar with FinCEN via the FBAR, must now brace themselves for more U.S. reporting requirements. Like the FBAR, not complying with the CTA carries stiff penalties. These range from $500 to $10,000 per violation and can include imprisonment.

Foreign reporting companies can be corporations, LLCs, or other entities formed under the law of a foreign country registered to do business in any U.S. state or tribal jurisdiction. Foreign entities registered as doing business in or paying sales tax to a U.S. state could be readily identified by FinCEN as subject to this new reporting requirement. As with domestic reporting entities, there are exceptions; however, a foreign entity could fail to meet the large operating company exception by not having a physical presence in the U.S.

In November 2023, FinCEN agreed to allow reporting companies to use a FinCEN identifier instead of information about a specific beneficial owner in specific circumstances. This could benefit individuals with ownership in multiple reportable entities. Tax practitioners working with multinational entities need to grasp the nuances of the CTA as it applies to foreign entities.

Listen as our panel of international tax reporting experts explains how the BOI reporting requirements impact foreign entities.



  1. Corporate Transparency Act for foreign reporting companies: introduction
  2. Due dates
  3. Foreign reporting companies
  4. Penalties
  5. Exceptions
  6. Privacy Issues
  7. Reporting requirements
  8. Utilizing FinCEN identifiers
  9. Best practices


The panel will cover these and other key issues:

  • What foreign entities must report BOI?
  • What penalties could be assessed if an entity does not report BOI?
  • When should an owner consider obtaining a FinCEN identifying number?
  • What exceptions to the CTA reporting requirements are there for foreign companies?


Adrion, Harold
Harold Adrion


Mr. Adrion specializes in international tax. He has advised U.S. and foreign-based multi-national publicly and...  |  Read More

Granwell, Alan
Alan Winston Granwell

Of Counsel
Holland & Knight

Mr. Granwell has been practicing in international taxation for more than 45 years and previously was director of the...  |  Read More

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