This article was originally posted on Steve Leimberg’s Business Entities Email Newsletter Archive Message #282.
On November 8th, the Treasury Department dashed the hopes of a great many professionals who have wished to receive news that implementation of the Corporate Transparency Act reporting requirements would be moved back, or made significantly more lenient to take into account the lack of complete guidance and the many issues that are still outstanding.
The most important thing that the November 8th release tells us, indirectly, is that as matters sit today, the Treasury Department appears intent on maintaining the existing effective dates, and requiring strict compliance with the law and the regulations as they evolve. More than 30 organizations recently wrote treasury encouraging deferral of the effective dates but relying on the hope that will happen, rather than preparing, may prove mistaken.
The new release makes it clear that the Treasury Department is well aware of its obligation to carefully consider “each and every comment” that was received with respect to the Proposed Regulations and to give thoughtful discussion to these.
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