tag:blogger.com,1999:blog-6398232680738279469.post5436718305055074902..comments2024-03-12T07:30:17.846-07:00Comments on The Tax Times: US Pressured For Beneficial Ownership RulesRonald A. Marini, Esq.http://www.blogger.com/profile/14304486100168506240noreply@blogger.comBlogger1125tag:blogger.com,1999:blog-6398232680738279469.post-21705648717740132502016-04-18T07:26:26.327-07:002016-04-18T07:26:26.327-07:00According to RIA - Thompson Reuters
Two Treasury ... According to RIA - Thompson Reuters<br /><br />Two Treasury officials, have recently highlighted a number of the efforts being made by the Department to both enhance financial transparency and curtail tax evasion. They offered a preview of proposed regs that are expected to be released soon that would require foreign-owned limited liability companies (LLCs) to disclose their beneficial owners, as well as a preview of forthcoming final “Customer Due Diligence” regs.<br />Forthcoming guidance provided information on ways that Treasury is looking to enhance transparency and reduce opportunities for tax evasion. This forthcoming guidance will be specifically targeted at two points in time, when an account is opened at a financial institution, and when a company is formed (or when company ownership is transferred). <br />Treasury is expecting to, in the near future, issue proposed regs that would require foreign-owned Limited Liability Companies (LLCs) to obtain a tax identification number which will disclose their beneficial owner(s). This additional measure of transparency would strengthen IRS's ability to prevent foreign entities from facilitating U.S. tax avoidance. <br />Treasury is also in the process of finalizing a Customer Due Diligence (CDD) rule, the proposed version of which was issued in proposed form on Aug. 4, 2014 (the “proposed CDD rule”). The purpose of this rule would be to “deny bad actors the ability to exploit the anonymity provided by the use of legal entities to engage in financial crimes.” <br />The proposed CDD rule would require covered financial institutions to collect ownership information for legal entity customers upon opening an account. “Beneficial owners” would be identified based on a 2-prong test to identify individuals with substantial equity ownership interests (defined as direct or indirect ownership of 25% or more equity interests of a legal entity customer; the ownership prong) and with actual managerial control (the control prong).<br />Ronald A. Marini, Esq.https://www.blogger.com/profile/14304486100168506240noreply@blogger.com