Author: Paul Millen

Is CRS Enforcement Baring Teeth?

The Case: For much of the decade’s winding course of CRS, enforcement measures have been threatened but rarely fulfilled. That seems to be changing. There has not been a new order from the OECD to adopt more draconian policies nor any evidence of a collective resolution by Participating Jurisdictions to…

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The End of the CTA?

The case On 21 March, the Treasury Department issued a new interim administrative rule for the Corporate Transparency Act (CTA), eliminating disclosure requirements for both any US Reporting Companies and any US beneficial...

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CTA Injunction Reinstated!

The case On 26 December, in the latest in a series of whipsawing rulings from the federal judges handling the Texas Top Cop Shop case, a second appellate panel reversed the first panel’s decision from 23 December (i.e....

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