The Corporate Transparency Act (the CTA) requires business entities newly created pursuant to state law to fully and publicly identify their beneficial owners.  This recent federal enactment (and the even more recent Department of Treasury regulations promulgated thereunder) is intended to thwart criminals, terrorists, and other evildoers who might cloak their nefarious schemes behind the mundane facades of seemingly legitimate corporations, limited partnerships, and LLCs.

Notwithstanding its lofty objective, the statutory regime has been severely questioned by those who claim that it ranges far beyond Congress’s authority to legislate.  See U.S. Const., art. I, § 8.