Reporting Corporate Trustees of Reporting Companies for the Corporate Transparency Act

If the trustee of a trust that owns an reporting company is an entity, do we trace back to the individuals that are the trustee’s beneficial owners?
Beneficial Owners are only individuals, so unless that entity is exempt, you always trace up to the entities owners.
When a trust is involved, even if the trustee is an entity, you must report all individuals with Substantial Control AND analyze grantors, beneficiaries, and trustees.
If the trustee is a Texas LLC, then it would need to be registered with the Texas Department of Banking as a trustee to operate as such. This likely would lead to the trustee LLC to be exempt from reporting the Beneficial Owners under the Ownership Interest, but not under the Substantial Control test.
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Strohmeyer Law is a law firm based in Houston, Texas, specializing in tax law, estate planning, and probate law.
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