Clifford Chance

Corporate Transparency Act- Implementing New Requirements on U.S. Real Estate Businesses

February 20, 2024

Real Estate Investment Trusts and Other Property Holding Arrangements within Scope

As of January 1, 2024, it is estimated that more than 32 million legal entities are now required to file certain information with the U.S. Government about the persons that own and control them. The requirement is part of a broader effort to make it easier for law enforcement to investigate illicit activities and associated money laundering through the use of companies and other legal structures.

Implementation of the rule may be relatively straightforward in some circumstances, but not in others, including situations involving legal structures regularly used to hold real property.

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