CTA and Non-U.S. Entities: January 1, 2025 BOI Reporting Deadline, Administrative Impact, Penalties

Mr. Granwell has been practicing in international taxation for more than 45 years and previously was director of the Treasury Department’s Office of International Tax Affairs.

Ms. Skinner is a Private Wealth Family Fiduciary Services Director based in Holland & Knight's Boston office. She has 10 years of experience providing estate planning, estate administration and trust administration services to high-net-worth clients. Ms. Skinner focuses on providing support to clients with complex family estate plans and high maintenance asset structures to ensure that administration is carried out properly. She maintains relationships and provides support to families and fiduciaries in administering their complex lives by working collaboratively with outside professionals, including accountants, insurance agents, financial advisors and client family offices, to facilitate coordinated action on a client's behalf. She tracks key dates for required entity maintenance activities and coordinates with the client's team of advisors to timely complete administration items relating to trust annuities, promissory notes, life insurance policies, real estate, art, and corporate entities. Ms. Skinner and the family fiduciary services team also provide bill pay services, account reporting, and facilitate document sharing, including secure file sharing for critical documents. She is also a member of Holland & Knight's Corporate Transparency Act (CTA) Team, which focuses on the recently enacted CTA. Ms. Skinner is familiar with the CTA reporting requirements for corporate entities, and in particular with the beneficial owner disclosure requirements when a trust has an ownership interest or substantial control over a reporting company. 

Mr. Titens is a corporate attorney in Holland & Knight's Dallas office. He represents U.S. and international clients in structuring, negotiating and implementing mergers and acquisitions (M&A) as well as joint ventures. Mr. Titens also represents private equity funds and portfolio companies in formation, financing and M&A transactions. He frequently represents Mexican and other international clients in M&A, foreign investment and other business transactions. He was a resident in the firm’s Monterrey, Mexico, office from 1993 to 1997. Mr. Titens also focuses on cybersecurity issues, including breach preparedness and responses, and previously served as co-chair of the firm’s Cybersecurity and Data Privacy Group.

Mr. Zagaris has advised individuals, entities and governments on international business, especially the regulatory and enforcement aspects. He has worked on tax controversy matters, including representing individuals on voluntary disclosures, audits, and litigation, as well as consulting and serving as an expert witness in criminal trials for defendants and the U.S. government. Since 1981, he has also represented foreign governments in international tax and financial services, including advising and helping negotiate income tax, tax information exchange agreements, and bilateral investment treaties. Mr. Zagaris’ practice has included a substantial amount of money movement issues, especially international ones. His work includes advising businesses on developing and implementing anti-money laundering due diligence plans. He has trained prosecutors, regulatory, and law enforcement officials on prosecuting money laundering and recovery of assets. Mr. Zagaris’ practice includes counseling on a wide variety of criminal, especially white collar, work. He has handled evidence gathering and extradition cases and cases involving prisoner transfer applications. His criminal work has included counseling on extradition and international evidence gathering cases, testifying as an expert in international criminal cases involving money laundering and tax crimes, and counseling of witnesses for grand jury investigations.