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Corporate Transparency Act for Trusts and Estates

Determining Reporting Responsibilities for Trustees, Fiduciaries, and Beneficiaries

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

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Conducted on Wednesday, February 28, 2024

Recorded event now available

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This webinar will review the key requirements of the Corporate Transparency Act (CTA) with particular focus on the perspective of trusts, estates, beneficiaries, fiduciaries, and trustees and delve into what is required under the CTA, examples of best practices in satisfying these requirements, and penalties for non-compliance.


The CTA requires beneficial ownership information reporting for entities unless an exception is met. The CTA is wrought with complications and unanswered questions, particularly for trusts, estates, and high net worth individuals. There are 23 exemptions from the definition of a reporting company as defined under the CTA. However, FinCEN's FAQs include this statement: "[a] domestic entity such as a statutory trust, business trust, or foundation is a reporting company only if it was created by the filing of a document with a secretary of state or similar office." Further, even if a trust does not file a document with the secretary of state, it could be considered a beneficial owner if it exercises substantial control or owns 25 percent or more of a reporting company.

High net worth individuals often choose LLCs and trusts to transfer wealth and protect their privacy. Some worry that the privacy obtained will now be thwarted. Perhaps most worrisome is whose information must be reported. Additionally, such requirements could have broader impacts, as an investment company, asset management company, or individual could function as a trustee. The penalties for non-filing are severe. Penalties for willful failure to file can amount to $500 per day/$10,000 per violation. Criminal penalties include imprisonment for up to two years. Fiduciary advisers must fully understand how the new CTA requirements impact beneficiaries and trustees.

Listen as our panel of wealth transfer experts analyzes the CTA's requirements as they pertain to trusts and estates.



  1. CTA for trusts and estates: introduction
  2. Reporting requirements
  3. Responsible reporting party
  4. Completing the form
  5. Penalties for noncompliance
  6. Best practices


The panel will review these and other critical issues:

  • Who is reported as the beneficial owner of a trust?
  • What penalties could be assessed for not complying with the CTA?
  • When is a trust subject to the reporting requirements under the CTA?
  • What are the responsibilities of fiduciaries, beneficiaries, and trustees under the CTA?


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

Smith-Sandy, Shekida
Shekida Anna Smith-Sandy

Paul, Weiss, Rifkind, Wharton & Garrison

Ms. Smith-Sandy maintains an interdisciplinary practice, advising clients on regulatory issues under federal and state...  |  Read More

Zuks, Rebecca
Rebecca M.G. Zuks

Paul, Weiss, Rifkind, Wharton & Garrison

Ms. Zuks is an associate in the Personal Representation Department at Paul, Weiss, Rifkind, Wharton & Garrison...  |  Read More

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