Tax Impacts

On December 23, 2021, the United States (“U.S.”) Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced amendments to the Bank Secrecy Act (“BSA”) penalty regulations to remove certain civil penalty language (previously, 31 C.F.R. § 1010.820(g)), despite FinCEN’s previous failure to modify the regulations after the enactment of the American Jobs Creation Act of 2004 (“American Jobs Creation Act”), Pub. L. No. 108-357, § 821, 118 Stat. 1418 (2004).

Earlier this month, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) to implement the beneficial ownership information reporting requirements set forth in Section 6403(a) of the Corporate Transparency Act, which was enacted as part of the National Defense Authorization Act of Fiscal Year 2021.