Tax & Wealth Services Report Blog
Updates and Analysis on Domestic and International Tax and Estate Planning Issues
The Tax & Wealth Services Report, authored by Bilzin Sumberg's private wealth and tax attorneys, provides updates and analysis for domestic and international clients.
Preparation of the "Sunset" and Estate Planning in an Uncertain Economic Climate for High Net Worth Families
With economic uncertainty rising and the TCJA's gift and estate tax exemption set to sunset at the end of 2025, high net worth families should act now to leverage planning strategies. Depressed asset values, high interest rates, and potential tax changes make this a critical window to transfer wealth efficiently. Early planning can minimize estate taxes and secure financial legacies despite market volatility.
Corporate Transparency Act: U.S. Treasury Issues Interim Final Rule and New Deadlines
On March 21, 2025, FinCEN issued an Interim Rule that significantly narrows the scope of the Corporate Transparency Act. Under the new rule, domestic entities and U.S. persons are no longer required to file beneficial ownership reports, and enforcement against them has been suspended. Only certain foreign entities with non-U.S. beneficial owners remain subject to the CTA’s requirements. A 60-day comment period is now open, with a final rule expected later this year. Learn more about the Interim Rule and its implications.
Treasury Department and FinCEN Announce Drastic Limits on Enforcement of Corporate Transparency Act
On March 2, 2025, the Treasury Department announced that it will not enforce penalties for BOI reporting violations under the Corporate Transparency Act—both before and after upcoming rule changes take effect. While this reduces regulatory pressure on U.S. businesses, non-U.S. companies may still face enforcement. Learn more about FinCEN’s and the US Treasury Department's evolving BOI reporting requirements.
Corporate Transparency Act is Back in Effect – Only 30 Day Extension!
Following a federal court ruling, the Corporate Transparency Act has been reinstated and FinCEN has announced it has extended the deadline for most reporting companies to file the beneficial ownership information (BOI) report until March 21, 2025. For reporting companies that have not yet filed a BOI report and are required to do so they should take immediate action to file the BOI report to avoid applicable reporting penalties.
Corporate Transparency Act: “Stay” Put
The U.S. Supreme Court has granted the U.S. government’s motion to stay a nationwide injunction prohibiting enforcement of the Corporate Transparency Act (“CTA”). Because a separate nationwide injunction order issued by a different U.S. federal court is still in place, the Financial Enforcement Crimes Network (“FinCEN”) has stated that it will continue to not enforce the CTA for the time-being.
CTA: Gone Away?
A federal court has issued a nationwide injunction temporarily suspending enforcement of the Corporate Transparency Act (CTA) reporting requirements. While this pause relieves immediate filing obligations, companies should continue preparing in case the injunction is lifted and coordinate with their legal counsel accordingly. Learn more about this critical development and how it affects reporting companies.
Moore v. U.S.: How the U.S. Supreme Court Uses a Jedi Mind Trick to Resolve the Case
The U.S. Supreme Court (“the Court”) has finally issued its decision in Moore v. U.S., No. 22-800 (“Moore”). The Moore case involved individual taxpayers who owned shares in a controlled foreign corporation (“CFC”) and were subject to the so-called “transition tax” of Internal Revenue Code Section (“IRC Sec.”) 965. In the end, the Court upheld the constitutionality of IRC Sec. 965, stating that “Congress has long taxed shareholders of an entity on the entity’s undistributed income, and it did the same with [IRC Sec. 965].