Category: USA/FATCA

The Case: The new US federal disclosure requirements for unfinanced purchases (or other transfers) of residential real estate by entities, known as the Residential Real Estate Rule, are now in force. Following the issuance of a Notice of Proposed Rule-Making on 7 February 2024 and the adoption of the final…

The Case: On 26 January 2026, the Swiss State Secretariat for International Finance (“SIF”) posted on its website a new deadline for the implementation of the Model 1 FATCA Intergovernmental Agreement (“IGA”). Accordingly, Switzerland’s conversion from a Model 2 IGA to a Model 1 IGA will be activated on 1…

The Case: On 16 December 2025, the United State Eleventh Circuit Court of Appeals reversed the decision in NSBU v. Yellen, which had found the Corporate Transparency Act (CTA) to be an unconstitutional exercise of congressional power. Under the 2021 law, the US Congress established a federal registry requiring most…

The Case: In 2024, New York enacted its own state-level Beneficial Ownership (BO) Registry based on the federal version that was supposed to come into effect on 1 January of this year. The federal BO Registry established under the Corporate Transparency Act (CTA) remains in limbo since the issuance of…

The case On 27 February FinCEN issued a notice – not posted to their website yet – that “it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or...

The case On 23 January 2025, the United State Supreme Court issued an 8-1 opinion staying the original injunction issued by the US Federal District Court in the Eastern District of Texas on 3 December 2024. Accordingly, the...

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....

The case On 23 December, the US Court of Appeals for the Fifth Circuit lifted the nationwide injunction against the Corporate Transparency Act. Thus, the original deadlines are legally back in effect. However, FinCEN opted to...

The case On 3 December, a US Federal District Court in the Eastern District of Texas issued an order granting a nationwide preliminary injunction against enforcement of the Corporate Transparency Act. In observance of this...

The case Anyone with US underlying companies shall be informed. Source: Paul Millen The commentary Paul has written many blogs on the CTA if you’re interested. This publication has been prepared solely for information...

The case The recent decision by the 11th Circuit Appellate Court in United States v. Isac Schwarzbaum introduces a significant constitutional restraint on penalties imposed for violations of Foreign Bank Account Reporting (FBAR)...