FinCEN’s New Residential Real Estate Reporting Rule: What Attorneys Need to Know for 2026

Alan Winston Granwell | Holland & Knight

Alan Granwell is an attorney in Holland & Knight’s Washington, D.C., office, with more than 50 years of experience in international taxation. In his long and wide-ranging career, he has represented multinational corporations and globally oriented high-net-worth clients in a broad array of international tax planning, compliance and controversy matters, including serving as an expert witness.

Mr. Granwell also advises on tax transparency initiatives, including the Corporate Transparency Act (which will have widespread application to privately held companies and their beneficial owners), the Foreign Account Tax Compliance Act, the Common Reporting Standard and the U.S. Department of Justice Swiss Bank Program.

In the early 1980s, Mr. Granwell was the International Tax Counsel and Director, Office of International Tax Affairs, U.S. Department of the Treasury. In that capacity, Mr. Granwell was the senior international tax adviser at the Treasury Department and was responsible for advising the Assistant Secretary for Tax Policy on legislation, regulatory and administrative matters involving international taxation and directing the U.S. tax treaty program.

Mr. Granwell began his career working at Wall Street law firms. He then moved to Washington, D.C., to accept his government appointment to work for the Treasury Department. Thereafter, he returned to private practice in Washington, D.C. Prior to joining Holland & Knight, Mr. Granwell was a tax attorney for a boutique international tax law firm.

Mr. Granwell is a Fellow of the American College of Tax Counsel and a well-known, frequent commentator and lecturer on international tax matters. He has authored numerous articles for publications, both in the United States and abroad. He has made presentations for the American Bar Association, Section of Taxation, the International Bar Association, the International Fiscal Association, the Society of Trust and Estate Practitioners (STEP) and other organizations in numerous countries around the world. Mr. Granwell also is an active member of the STEP, particularly organizing, moderating and presenting at educational webinars, and is a former chair of the Mid Atlantic Branch, the current Co-Director of Programs for the Mid Atlantic Branch, and a frequent contributor to STEP USA Alerts.

Bruce Zagaris | Berliner Corcoran & Rowe

Bruce Zagaris has advised individuals, entities and governments on international business, especially the regulatory and enforcement aspects.

Mr. Zagaris has worked on tax controversy matters, including representing individuals on voluntary disclosures, audits, and litigation, as well as consulting and serving as an expert witness in criminal trials for defendants and the U.S. government. Since 1981, he has also represented foreign governments in international tax and financial services, including advising and helping negotiate income tax, tax information exchange agreements, and bilateral investment treaties.

His practice includes counseling on a wide variety of criminal, especially white collar, work. He has handled evidence gathering and extradition cases and cases involving prisoner transfer applications. His criminal work has included counseling on extradition and international evidence gathering cases, testifying as an expert in international criminal cases involving money laundering and tax crimes, and counseling of witnesses for grand jury investigations.

Since 1985, he has edited the International Enforcement Law Reporter, a monthly publication.

His practice has included a substantial amount of money movement issues, especially international ones. He has counseled defendants in criminal cases and served as a consultant and expert witness for criminal defendants. His work includes advising businesses on developing and implementing anti-money laundering due diligence plans. He has trained prosecutors, regulatory, and law enforcement officials on prosecuting money laundering and recovery of assets.

Mr. Zagaris is fluent in Spanish and Portuguese and has a working knowledge of French.

Jonathan N. Halpern | Holland & Knight

Jonathan N. Halpern is a seasoned litigator who draws on his extensive experience in a wide array of white collar criminal defense matters, and as a former federal prosecutor in the Southern District of New York (SDNY), to represent corporations and individuals in investigations and prosecutions spanning a breadth of criminal issues. He has litigated complex criminal and civil matters, but a substantial portion of his defense practice entails engaging with prosecutors and regulatory lawyers to resolve federal and state criminal and agency investigations for his clients away from the public spotlight. A legal strategist and problem solver, Mr. Halpern is a skillful and relentless negotiator and advocate both in court and behind the scenes, where he has quietly achieved client success in securing the dismissal of federal criminal felonies. Prosecutors, clients and adversaries have credited him for his creativity in proposing resolutions to challenging issues.

Mr. Halpern represents corporate and individual clients in internal and government investigations in a wide array of criminal, cross-border and compliance issues. Business and educational institutions and individuals turn to Mr. Halpern to represent them in a broad array of matters encompassing financial services; cybersecurity; Foreign Corrupt Practices Act (FCPA); false claims and other healthcare matters; securities, commodities, and tax, among other issues. He also handles representation and defense in investigations and litigation involving allegations of sexual assault, harassment and workplace misconduct. Mr. Halpern represents clients in federal and state court, as well as in matters involving U.S. Attorney’s Offices, New York State Attorney General’s Office, New York County District Attorney’s Office, U.S. Department of Justice (DOJ), U.S. Department of the Treasury, U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC). His clients span diverse industries from cybersecurity, banking, investor funds, mortgage and other financial services to pharmaceutical and healthcare, media, energy services, manufacturing and retail.

In addition, Mr. Halpern is experienced in representations involving allegations of wrongdoing in the workplace and has successfully defended executives in investigations and litigation alleging sexual assault, harassment and other misconduct.

Mr. Halpern handles substantial pro bono legal work, including immigration asylum cases, and he has successfully secured asylum for individuals seeking to escape persecution in their homelands. One escapee, who was arrested at the U.S. border and detained for approximately nine months, was granted asylum – and his freedom – after Mr. Halpern litigated his case and prevailed at trial. Mr. Halpern agreed to take the case after several lawyers had declined to do so. More recently, he succeeded in securing asylum for the client’s spouse and children, assisting them to be reunited after years apart. After extensive work by Mr. Halpern and a firm associate, another pro bono client recently was granted asylum for fear of being persecuted in a former Soviet republic because of his sexual orientation. For his commitment and achievements, Mr. Halpern was named a Holland & Knight Public & Charitable Service All Star in 2019 and has consistently been named a Pro Bono All Star.

Mr. Halpern’s tenure as a federal prosecutor in the SDNY included service as chief of the Major Crimes Unit. In that position, he supervised approximately 25 experienced federal prosecutors in investigations and prosecutions of international bribery, money laundering, healthcare and tax fraud, computer crimes, Bank Secrecy Act violations and other complex, large-scale financial crimes. As a federal prosecutor, Mr. Halpern investigated and prosecuted white collar crimes involving public corruption, extortion, money laundering, federal tax violations, bank fraud and wire, mail and healthcare fraud. He served as lead prosecutor in several high-profile matters, including the investigation of the presidential pardon of Marc Rich, and supervised the investigation of corruption allegations in the United Nation’s Oil for Food Program.

Michael C. Titens | Holland & Knight

Michael Titens is a corporate attorney in Holland & Knight’s Dallas office.

Mr. Titens represents U.S. and international clients in structuring, negotiating and implementing mergers and acquisitions (M&A) as well as joint ventures. He also represents private equity funds and portfolio companies in formation, financing and M&A transactions.

Mr. Titens frequently represents Mexican and other international clients in M&A, foreign investment and other business transactions. He was a resident in the firm’s Monterrey, Mexico, office from 1993 to 1997.

Mr. Titens also focuses on cybersecurity issues, including breach preparedness and responses, and previously served as co-chair of the firm’s Cybersecurity and Data Privacy Group.

I. Scope and purpose of FinCEN’s Residential Real Estate Reporting Rule | 2:00pm – 2:15pm

II. Defining reportable transfers, covered property, and key exemptions | 2:15pm – 2:30pm

III. Identifying the reporting person: Cascades, designation agreements, and attorney exposure | 2:30pm – 2:45pm

IV. Beneficial ownership determinations and valuation-related  challenges | 2:45pm – 3:00pm

Break | 3:00pm – 3:10pm

V. Procedural compliance: Real estate report content, timing, and filing mechanics | 3:10pm – 3:25pm

VI. Enforcement risk, penalties, and ongoing legal challenges | 3:25pm – 3:40pm