Trusts and Estates

Ca. Trs. & Estates Quarterly VOLUME 30, ISSUE 1, 2024

PROPOSED RULE: FINCEN PROPOSES REQUIRING ESTATE PLANNERS TO REPORT TRANSFERS OF RESIDENTIAL REAL PROPERTY TO TRUSTS

Written by By Michael Gorini, Esq. and Robert Gorini, Esq.

I. SYNOPSIS

The Financial Crimes Enforcement Network ("FinCEN"), a bureau of the U.S. Department of the Treasury, proposed a new rule relating to residential real property transfers to specified legal entities including trusts.01 This article is intended to alert trust and estate practitioners of the proposed rule (as currently drafted), as it will affect almost all estate planning attorneys. This proposed new rule (referred to herein as "the proposed rule") would apply when an attorney creates a trust and prepares or records the deed which transfers residential real property thereto, subject to some potentially notable exceptions.

The proposed rule is separate from the Corporate Transparency Act ("CTA"), which was effective January 1, 2024. The proposed rule would be added to chapter X of title 31 of the Code of Federal Regulations as a new part 1031.02

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