Alerts
Pay To Play Implications of VP Candidacy of Minnesota Governor Tim Walz
August 6, 2024
Earlier today, Vice President Kamala Harris selected Minnesota Governor Tim Walz as her running mate. As governor, Walz serves as the Chair of the Minnesota State Board of Investment (SBI), which has authority with respect to investments by various Minnesota pension plans. Thus, any contribution to, or fundraising or solicitation on behalf of, the Harris/Walz campaign should be evaluated for implications under Rule 206(4)-5 of the Advisers Act (the "Pay to Play Rule").
For more information, see Schulte’s Pay to Play Rule refresher.
Practices
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Alerts
On July 24, 2024, the US Department of Treasury's Financial Crimes Enforcement Network (“FinCEN”) issued updates to its Frequently Asked Questions (“FAQs”) [1] regarding the beneficial ownership information (“BOI”) reporting requirements of the Corporate Transparency Act (collectively, with its implementing regulations, the “CTA”).[2] These FAQs provide (i) clarity on the type of taxpayer identification number (“TIN”) information required to be reported by an entity that is disregarded as an entity that is separate from its sole tax owner for US federal tax purposes (“DRE”) and (ii) relief to certain types of entities relating to this TIN reporting obligation.
Alerts
The recently enacted Corporate Transparency Act (“CTA”) establishes mandatory federal reporting requirements for any legal entity registered with the secretary of state or any similar office. If you own or have management responsibility over one or more limited liability companies, limited partnerships, corporations or other similar entities or, if any trust of which you are a grantor, trustee or beneficiary owns or has management responsibility over one or more limited liability companies, limited partnerships, corporations or other similar entities, you may be subject to the new filing requirements of the CTA. For any entity created before Jan. 1, 2024, beneficial ownership reports must be filed with the Financial Crimes Enforcement Network (FinCEN), a bureau of the Department of Treasury, by Dec. 31, 2024. A copy of the Alert we circulated on Jan. 31, 2024, outlining the key features of the CTA, can be found here. There are financial and, in some cases, criminal penalties for failure to file a report. Please reach out to us immediately if you need assistance determining whether you have to file a beneficial ownership report. We need to hear from you no later than Aug. 31, 2024, to be able to provide timely assistance on this matter.
Alerts
On July 24, 2024, the US Department of Treasury's Financial Crimes Enforcement Network (“FinCEN”) issued updates to its Frequently Asked Questions (“FAQs”) [1] regarding the beneficial ownership information (“BOI”) reporting requirements of the Corporate Transparency Act (collectively, with its implementing regulations, the “CTA”).[2] These FAQs provide (i) clarity on the type of taxpayer identification number (“TIN”) information required to be reported by an entity that is disregarded as an entity that is separate from its sole tax owner for US federal tax purposes (“DRE”) and (ii) relief to certain types of entities relating to this TIN reporting obligation.
Alerts
The recently enacted Corporate Transparency Act (“CTA”) establishes mandatory federal reporting requirements for any legal entity registered with the secretary of state or any similar office. If you own or have management responsibility over one or more limited liability companies, limited partnerships, corporations or other similar entities or, if any trust of which you are a grantor, trustee or beneficiary owns or has management responsibility over one or more limited liability companies, limited partnerships, corporations or other similar entities, you may be subject to the new filing requirements of the CTA. For any entity created before Jan. 1, 2024, beneficial ownership reports must be filed with the Financial Crimes Enforcement Network (FinCEN), a bureau of the Department of Treasury, by Dec. 31, 2024. A copy of the Alert we circulated on Jan. 31, 2024, outlining the key features of the CTA, can be found here. There are financial and, in some cases, criminal penalties for failure to file a report. Please reach out to us immediately if you need assistance determining whether you have to file a beneficial ownership report. We need to hear from you no later than Aug. 31, 2024, to be able to provide timely assistance on this matter.
Alerts
On July 24, 2024, the US Department of Treasury's Financial Crimes Enforcement Network (“FinCEN”) issued updates to its Frequently Asked Questions (“FAQs”) [1] regarding the beneficial ownership information (“BOI”) reporting requirements of the Corporate Transparency Act (collectively, with its implementing regulations, the “CTA”).[2] These FAQs provide (i) clarity on the type of taxpayer identification number (“TIN”) information required to be reported by an entity that is disregarded as an entity that is separate from its sole tax owner for US federal tax purposes (“DRE”) and (ii) relief to certain types of entities relating to this TIN reporting obligation.