Understanding the New York Limited Liability Company Transparency Act Requirements, Implications & Uncertainties

Alan Winston Granwell | Holland & Knight LLP

Alan Granwell is a senior attorney in Holland & Knight’s Washington, D.C., office whose more than five decades of experience in international taxation uniquely position him to advise on emerging transparency regimes such as the New York Limited Liability Company Transparency Act (NY LLCTA). His career has centered on helping multinational enterprises and globally oriented high-net-worth individuals navigate complex compliance landscapes, including beneficial ownership reporting, cross-border disclosure rules, and evolving tax transparency mandates. Mr. Granwell has served as an expert witness and trusted advisor on the Corporate Transparency Act, FATCA, the Common Reporting Standard, and other foundational frameworks that inform state-level efforts like the NY LLCTA.

A former International Tax Counsel and Director of the Office of International Tax Affairs at the U.S. Department of the Treasury, Mr. Granwell brings firsthand regulatory insight into how transparency legislation is crafted, interpreted, and enforced. At Treasury, he was the senior advisor to the Assistant Secretary for Tax Policy and oversaw international tax legislation, regulatory matters, and the U.S. tax treaty program—experience that directly shapes his analyses of federal-state alignment issues, implementation challenges, and the broader policy uncertainties raised by the NY LLCTA.

In private practice, Mr. Granwell has become a leading commentator and lecturer on global tax compliance and transparency initiatives. He is a Fellow of the American College of Tax Counsel and an active leader in the Society of Trust and Estate Practitioners (STEP), where he frequently organizes and presents educational programs. His extensive authorship, international speaking engagements, and long-standing commitment to practitioner education underscore his deep understanding of the legal, operational, and policy implications surrounding beneficial ownership reporting—expertise highly relevant to organizations seeking clarity on the NY LLCTA’s requirements and its interplay with federal transparency laws.

Thomas E. Rutledge | Stoll Keenon Ogden PLLC

Tom is a leading authority on limited liability companies and business organization law whose experience is highly relevant to understanding the requirements, implications, and uncertainties of the New York Limited Liability Company Transparency Act (NY LLCTA). A long-time member of Stoll Keenon Ogden’s business services group, Tom has spent more than three decades shaping, interpreting, and applying the law of LLCs and other business entities. His early recognition of LLCs as a transformative organizational form—dating back to 1991—led to a career devoted to mastering their structure, governance, and statutory evolution. That depth of experience now informs his work guiding clients through beneficial ownership reporting obligations and the broader compliance challenges created by state and federal transparency laws.

As both a practitioner and a drafter of business entity legislation, Tom offers an uncommon perspective on how statutes like the NY LLCTA will function in practice. He has served as principal architect of numerous Kentucky acts governing corporations, partnerships, LLCs, and limited cooperative associations, and has played a national role in shaping entity law through the American Bar Association, the Uniform Law Commission, and the American Law Institute. This background allows him to assess not only what the NY LLCTA requires, but how its definitions, filing obligations, and enforcement mechanisms interact with long-standing principles of entity formation, agency, fiduciary duties, and dissolution. His extensive work as an expert witness—particularly in disputes involving LLC operating agreements, ownership conflicts, and governance failures—further equips him to anticipate areas where the Act may create uncertainty or litigation risk.

Tom’s recent focus on the Corporate Transparency Act (CTA) positions him at the center of the federal-state compliance conversation that the NY LLCTA amplifies. He regularly advises clients on entity selection, formation, governance drafting, mergers and acquisitions, Series LLC structures, and dispute resolution—experience that translates directly to helping organizations understand how the NY LLCTA aligns with, diverges from, or adds to CTA requirements. Whether guiding clients through beneficial ownership reporting, drafting operating agreements that mitigate potential disclosure-related disputes, or interpreting the interplay between state and federal definitions of control and ownership, Tom brings a sophisticated, statute-driven analysis essential for navigating the uncertainties surrounding New York’s new transparency regime.

Kevin L. Shepherd | Venable LLP

Kevin Shepherd is a nationally recognized real estate attorney whose leadership in regulatory compliance, entity structuring, and financial transparency makes his experience highly relevant to navigating the requirements and emerging uncertainties of the New York Limited Liability Company Transparency Act (NY LLCTA). His practice focuses on complex, high-value real estate transactions for major U.S. and global institutions, including development projects, corporate headquarters leases, acquisitions, and large-scale financing arrangements. Because many of these transactions involve layered ownership structures, single-purpose LLCs, and cross-jurisdictional investments, Kevin is deeply familiar with the operational realities that the NY LLCTA now affects—particularly how beneficial ownership reporting obligations may impact real estate deals, investment vehicles, and large institutional clients.

Beyond his transactional work, Kevin is a recognized national leader in the legal profession and a prominent voice on financial integrity and anti-money-laundering (AML) initiatives. As past treasurer of the American Bar Association, past president of the American College of Real Estate Lawyers, and former chair of the ABA Real Property, Trust and Estate Law Section, he has helped shape policy discussions at the intersection of real estate, corporate governance, and regulatory compliance. His extensive writing and international speaking on the role of lawyers in detecting and preventing money laundering and terrorist financing positions him at the forefront of the evolving transparency landscape—experience directly applicable to interpreting how laws like the NY LLCTA and the Corporate Transparency Act (CTA) affect entity formation and real estate capital flows.

Kevin’s leadership within Venable—serving as managing director of finance and chair of the firm’s Finance Committee—further underscores his sophisticated understanding of corporate structures, financial operations, and institutional risk management. As real estate entities, investors, and developers confront the new disclosure regime under the NY LLCTA, Kevin’s blend of transactional experience, policy involvement, and AML expertise provides critical insight into how the Act will influence deal structuring, ownership arrangements, compliance strategies, and the broader regulatory expectations placed on attorneys and their clients in high-value real estate environments.

Andrew J. Weiner | Pillsbury Winthrop Shaw Pittman LLP

Pillsbury Real Estate partner Andrew Weiner’s practice is global in scope, with a significant and sustained concentration on transactions in the New York metropolitan area.

Since 1976, Andrew has represented domestic and foreign clients in equity and debt transactions, the creation of real estate funds and joint ventures, and transactions involving distressed real estate.

Andrew’s practice has had a significant concentration in the hospitality and real estate investment trust (REIT) sectors, and in leasing. His clients have included funds, family offices, institutional lenders, universities, non-U.S. investors and New York City developers.

I. Background of N.Y. LLCTA| 1:00pm – 1:05pm

II. Interaction with Corporate Transparency Act | 1:05pm – 1:15pm

• Decoupling of certain CTA terms
• Incorporation of certain CTA definitions

III. What type of entity is a reporting company | 1:15pm – 1:25pm

IV. Which type of LLCS are subject to the exemption procedure | 1:25pm – 1:30pm

V. Which individuals are beneficial owners | 1:30pm – 1:35pm

VI. What information must be disclosed | 1:35pm – 1:45pm

VII. What are the filing due dates | 1:45pm – 1:50pm

VIII. What is the method of filing | 1:50pm – 2:00pm

Break | 2:00pm – 2:10pm

IX. What are the penalties for non compliance | 2:10pm – 2:20pm

X. Confidentiality of information | 2:20pm – 2:30pm

XI. How to determine who is a beneficial owner | 2:30pm – 2:40pm