Non-US-based investors face the disclosure regime of the Corporate Transparency Act. What do you need to know?
Non-US-based investors that own or invest in US real estate have never been free from disclosure requirements. But the disclosure regime has historically been relatively inobtrusive. The Federal government has been ratcheting up the scope of required disclosure, in part as a response to the terrorist attacks of 9/11 and to rising concerns about money laundering through real estate ownership.
On January 1, 2021, Congress enacted the Corporate Transparency Act (CTA), the most significant expansion in over twenty years of requirements to disclose the identity of individuals who own or control entities engaged in business in the US. While the CTA applies both to domestic and to some non-US-based entities, and is not limited to real estate activities, when fully implemented its effect on non-US-based investors and sponsors of commingled vehicles in which these investors participate will be substantial.
In this episode of the AFIRE Podcast, Andrew Weiner, Real Estate Practice Partner at Pillsbury, talks about the current state of the CTA—and what investors will need to watch for in the coming months.
Pillsbury Real Estate partner Andrew Weiner’s practice is global in scope, with a significant and sustained concentration on transactions in the New York metropolitan area.
Since 1976, Andrew has represented domestic and foreign clients in equity and debt transactions, the creation of real estate funds and joint ventures, and transactions involving distressed real estate.
Andrew’s practice has had a significant concentration in the hospitality and real estate investment trust (REIT) sectors, and in leasing. His clients have included funds, family offices, institutional lenders, universities, non-U.S. investors and New York City developers.
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