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It didn’t take very long for 2021 to bring about federal legislation that could significantly impact, or at least cause massive administrative headaches for, domestic and international private clients and their holding structures. The Corporate Transparency Act (the Act ) was enacted into federal law on January 1, 2021. With the close of the previous decade – a decade that brought the likes of FATCA, CRS, and other beneficial ownership and transparency laws around the world – it is not surprising that the United States is continuing to build on these global initiatives. This article first provides a brief overview of the Act and then raises some initial considerations and questions for private clients to start thinking about.