News & Analysis as of

U.S. Treasury Reporting Requirements

Snell & Wilmer

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti‑Money Laundering/Countering the Financing of Terrorism...more

Hone Maxwell

Understanding FATCA and Its Impact on Foreign Financial Institutions: Why Finding Financial Services as an American Abroad Can Be...

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As an American living abroad, you may have experienced firsthand the challenges of finding a financial institution willing to work with you. Whether it’s for opening a bank account, investing in local markets, securing a...more

Morrison & Foerster LLP

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

Husch Blackwell LLP

OBBBA Extends, Modifies Opportunity Zone Program

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One of the highly anticipated provisions of the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more

Orrick, Herrington & Sutcliffe LLP

Treasury revokes final rule following Congress’s repeal

On July 11, the IRS published a rule in the Federal Register revoking a rule the IRS had issued in December 2024 after the rule had been repealed by Congress under the Congressional Review Act. The final rule, “Gross Proceeds...more

Verrill

No Need to Report That Your Domestic Entity is Now Exempt from BOI Reporting Requirements

Verrill on

Through an Interim Final Rule that became effective March 26, 2025 (the “IFR”), the U.S. Treasury Department took action to exclude all U.S.-formed entities from the BOI[1] reporting regime under the Corporate Transparency...more

Seyfarth Shaw LLP

7 Key Changes to the Qualified Opportunity Zone Incentive Under the One Big Beautiful Bill Act

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On July 4, President Trump signed into law H.R. 1, the One Big Beautiful Bill Act (OBBBA), a sweeping 870-page piece of legislation that introduces significant changes across various areas of federal policy. While full...more

Conn Maciel Carey LLP

The One Big Beautiful Bill’s Overtime and Tax Provisions – Employer Consequences

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As we await the House of Representatives’ vote on the One Big Beautiful Bill, let’s highlight two key provisions that may soon impact employers and employees alike. The Senate bill under consideration before the House of...more

Seward & Kissel LLP

July 31 Deadline for BE-180 Reports

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The BE-180 is the quinquennial Benchmark Survey of Financial Services Transactions between U.S. Financial Services Providers and Foreign Persons (the “BE-180 Survey”) conducted by the U.S. Bureau of Economic Analysis (the...more

Orrick, Herrington & Sutcliffe LLP

Senators pen bipartisan letter arguing rescission of Treasury rule

On May 27, Sens. Sheldon Whitehouse (D-RI) and Charles Grassley (R-IA) wrote to the Treasury encouraging recission of the interim final rule requiring “foreign reporting companies,” but not domestic entities or U.S. citizens,...more

Eversheds Sutherland (US) LLP

Senators oppose FinCEN’s Interim Final Rule on the Corporate Transparency Act

On May 27, 2025, Senators Sheldon Whitehouse (D-RI) and Charles E. Grassley (R-IA) submitted a comment to US Treasury Secretary Scott Bessent expressing strong opposition to the Financial Crime Enforcement Network’s Interim...more

ArentFox Schiff

So Long Syria Sanctions? Not So Fast!

ArentFox Schiff on

On May 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25, “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain...more

Lathrop GPM

Administration Issues Cross-Agency Guidance Targeting Health Care Pricing and Focusing on Hospitals and Health Plans

Lathrop GPM on

On May 22, 2025, the U.S. Department of Health and Human Services, Department of Treasury and Department of Labor (the “Agencies”) announced new steps intended to “strengthen healthcare price transparency.” ...more

Williams Mullen

IRS Withdraws Reporting Requirements for Certain Basis-Shifting Transactions

Williams Mullen on

On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more

K&L Gates LLP

FinCEN's New Reporting Requirements for Nonfinanced Residential Real Estate Transactions

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Effective 1 December 2025, the Financial Crimes Enforcement Network (FinCEN) will implement comprehensive nationwide regulations aimed at increasing transparency and combating money laundering in the United States residential...more

Foley Hoag LLP

BE-10 Benchmark Survey of U.S. Direct Investment Abroad – Filings Due May 30 or June 30, 2025

Foley Hoag LLP on

Key Takeaways: - The U.S. Bureau of Economic Analysis (BEA) has announced that it is once again time to file the BE-10 Benchmark Survey of U.S. Direct Investment Abroad. The benchmark survey covers the universe of U.S....more

Fox Rothschild LLP

Trump and Congress Nullify IRS Reporting Rule for Digital Assets

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The federal rule that would have required crypto platforms to report users’ transactions to the IRS has officially been scrapped. President Trump signed a joint congressional resolution overturning the so-called DeFi...more

Troutman Pepper Locke

Practical Implications of the Interim Final Rule for BOI Reporting Under the CTA

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As we previously discussed, the Financial Crimes Enforcement Network (FinCEN) published an interim final rule (IFR) on March 26 that narrowed the beneficial ownership information (BOI) reporting requirements under the...more

Cooley LLP

Congress Repeals Digital Asset Regulations Applicable to Decentralized Finance Platforms

Cooley LLP on

In a January 27 client alert, we discussed final regulations issued on December 30, 2024, covering tax reporting requirements applicable to certain decentralized finance (DeFi) platforms operating as noncustodial brokers of...more

Fenwick & West LLP

UPDATE: Trump Signs Joint Resolution Repealing DeFi Broker Reporting

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On April 10, 2025, President Donald Trump signed a joint resolution to repeal the DeFi broker reporting regulations which were finalized in December in T.D. 10021....more

Pillsbury Winthrop Shaw Pittman LLP

CTA Deadline Approaching for Foreign Reporting Companies

The Corporate Transparency Act (CTA) was adopted by Congress in January 2021 and became effective on January 1, 2024. Under the CTA and the initial regulations implementing it, “reporting companies” (corporations, LLCs,...more

Tarter Krinsky & Drogin LLP

Changes to The Corporate Transparency Act Bring Major Shift to U.S. Reporting Requirements

Domestic Entities No Longer Required to Disclose Beneficial Ownership Information - The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule on March 21, 2025 (effective...more

Troutman Pepper Locke

OCC Notifies Congress of Major Email System Security Breach

Troutman Pepper Locke on

On April 8, the Office of the Comptroller of the Currency (OCC) officially notified Congress of a significant information security incident involving its email system. This notification, mandated by the Federal Information...more

Husch Blackwell LLP

FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons Under the CTA

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule (IFR) removing the requirement for U.S. domestic reporting companies and U.S. persons to report Beneficial Ownership...more

Miller Canfield

UPDATED: FinCEN’s New Interim Final Rule (1) Exempts Domestic Companies from Corporate Transparency Act Reporting and (2) Sets New...

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a new interim final rule (new IFR) significantly limiting the scope of reporting required under the...more

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