Lisa Gora, Member of the Firm, moderates a panel discussion, "The Corporate Transparency Act," hosted by the Health Law Section of the New Jersey State Bar Association (NJSBA).
Beginning Jan. 1, 2024, the Corporate Transparency Act (CTA) requires certain U.S. and foreign entities defined as "reporting companies" to report certain identifying information about themselves, their beneficial owners, and company applicants to FinCEN (the U.S. Dept. of the Treasury's Financial Crimes Enforcement Network) within a certain prescribed time period.
Failure to comply with the new reporting requirements will result in civil and criminal penalties. The CTA imposes a civil penalty of not more than $500 for each day that there is a willful failure to report complete beneficial ownership information or a willful provision of or willful attempt to provide false or fraudulent beneficial ownership information. Further, a person may face a fine of up to $10,000 and imprisonment.
The CTA includes several exemptions, which may mean some larger healthcare entities will not have to meet the reporting requirements. However, smaller healthcare entities are not likely to be exempt. Therefore, they must understand and comply with the new requirements. Smaller healthcare entities are not alone. Management service organizations (MSOs) that are owned in part by private equity and some joint venture arrangements may be required to report.
The panel will guide healthcare counsel on the CTA and what it means for healthcare entities, and will also provide an overview of the CTA and will discuss how the new CTA requirements apply to physician groups, physician-hospital joint ventures and other joint venture arrangements, and MSOs co-owned by private equity firms. The panel will offer best practices for meeting CTA requirements.
The panel will review these and other important considerations:
- Which healthcare entities will likely be most affected by the CTA's implementation and why?
- What exemptions may apply?
- How will the CTA's reporting requirements affect physician-hospital JVs and other transactions?
For more information, visit NJSBA.com.
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