The Corporate Transparency Act (CTA) went into effect January 1, 2024. Under the CTA, tens of millions of entities must file an initial report with FinCEN before the end of 2024, and millions of updated reports will need to be filed every year going forward. While FinCEN has provided guidance that helps define reporting company, beneficial owner, and company applicant, important issues remain unresolved. This presentation will focus on areas of the law where there is not enough guidance and where reasonable people disagree. It will also provide insight into some of the less commonly discussed areas of the CTA. Topics will include identifying beneficial owners where a trust owns a reporting company, who is considered a company applicant, and how to calculate the 30-day window to update a previously submitted Beneficial Ownership Information (BOI) report. We will also explore how to report when an exempt entity owns some or all of a reporting company.  Finally, this presentation will include a discussion of how to advise clients while the constitutionality of the CTA is being challenged.