Can a trustee be a beneficial owner?

Asked by: Kaelyn Monahan  |  Last update: July 27, 2025
Score: 4.6/5 (38 votes)

Trustee Ownership in General. Therefore, if 25% or more of a reporting company's equity is held in a trust, the trustee must be reported as a “beneficial owner” on the reporting company's BOI report, even though the trustee has no economic interest in the underlying trust assets.

Are trustees considered beneficial owners?

Depending on the specific circumstances, when a trust has an interest in a reporting company, the beneficial owners whose personal information must be reported to FinCEN could include a trustee, a direction advisor, a trust protector, a designated representative, a grantor, a beneficiary, any other individual acting on ...

Are trustees considered owners?

A common misunderstanding is that the trust owns the property within it. This is not really true. The trustee of the trust holds legal title to the trust property. The trust beneficiaries hold beneficial title to the trust property.

Who can be a beneficial owner?

In domestic and international commercial law, a beneficial owner is a natural person or persons who ultimately owns or controls an interest in a legal entity or arrangement, such as a company, a trust, or a foundation.

Do charitable trusts have beneficial owners?

Virtually all legal entity types—including a 501(c)3—have individuals who can be considered beneficial owners due to their substantial control over the organization. However, 501(c)3 organizations are exempt from CTA requirements and don't need to report BOI.

Who are the Beneficial Owners of a Trust for the Corporate Transparency Act?

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Who is exempt from the beneficial ownership rule?

Are some companies exempt from the reporting requirement? Yes, 23 types of entities are exempt from the beneficial ownership information reporting requirements. These entities include publicly traded companies meeting specified requirements, many nonprofits, and certain large operating companies.

Who owns the assets of a charitable trust?

When you die, the trust's remaining assets will pass to your charitable beneficiary. You may also name a non-charitable beneficiary to receive a portion of the trust proceeds. Once your beneficiary dies, their stake and proceeds will be passed on to the charitable recipient.

Who is not a beneficial owner?

In addition, “beneficial owner” does not include a minor child (although the information of their parent or guardian has to be reported); an individual acting as a nominee, intermediary, custodian, or agent of another individual; an employee acting solely as an employee; an individual whose only interest in the company ...

Who counts as a beneficial owner?

In banking, the beneficial owners of a legal entity are those individuals who have a large equity interest or control over the entity's financials. Banks are required to collect this information in order to prevent money laundering.

Who is the beneficial owner of an irrevocable trust?

For change in ownership purposes, the present beneficiary of an irrevocable trust is considered to be the owner of the present beneficial interest in property held by the trust.

Can a trustee be a beneficiary?

It is not unusual for the successor trustee of a trust to also be a beneficiary of the same trust. This is because settlors often name trusted family members or friends to both manage their trust and inherit from it.

What is the difference between a trustee and an owner?

In broad terms, a trust is an arrangement where the owner of property ("the settlor") transfers it to the ownership of another person ("the trustee"), on condition that the trustee uses the property only for the benefit of others ("the beneficiaries").

Is it better to be a trustee or beneficiary?

A trustee typically has the most control in running their trust. They are granted authority by their grantor to oversee and distribute assets according to terms set out in their trust document, while beneficiaries merely reap its benefits without overseeing its operations themselves.

What is classed as a beneficial owner?

For partnerships (other than a limited liability partnership), a beneficial owner is an individual who ultimately is entitled to, or controls more than 25% share of the capital/ profits or voting rights of the partnership, or otherwise exercises ultimate control over the management of the partnership.

What type of entity is a trustee?

The trustee is the individual or corporate entity that manages your trust and distributes your assets to the trust beneficiaries. As a fiduciary, the trustee must follow the instructions outlined in the trust document, managing, and distributing the trust assets in the best interests of the beneficiaries.

Is an executor a beneficial owner?

Since beneficiaries, settlors, executors and trustees can each be considered beneficial owners, the ownership interests held in an estate or trust could be considered simultaneously as owned or controlled by multiple persons.

Who is the beneficial owner of a trust?

A beneficial owner is an individual who ultimately owns or controls an entity such as a company, trust or partnership. 'Owns' in this case means owning 25% or more of the entity. This can be directly (such as through shareholdings) or indirectly (such as through another company's ownership or through a bank or broker).

How do I determine if I'm a beneficial owner?

Generally, someone who holds at least 25% of the capital stake, voting powers, and/or profit rights for an asset is considered a beneficial owner (or ultimate beneficial owner, if their ownership share is among the highest for that asset).

What is a legal owner but not a beneficial owner?

The owner at law may not be the same person as the beneficial owner. A beneficial owner is a person entitled to the benefit of the land and on their death the equitable interest may not pass in the same way as the legal ownership does.

Who is excluded from beneficial ownership?

Yes, 23 types of entities are exempt from the beneficial ownership information reporting requirements. These entities include publicly traded companies meeting specified requirements, many nonprofits, certain regulated companies, and certain large operating companies.

Who will be the beneficial owner?

(c) any person who exercises control over the management of the company or LLP. (b) holds the position of officer of the partnership.

Are trust accounts subject to beneficial ownership rules?

For those trusts that own or control, in whole or in part, reporting companies, the personal information of those reporting companies' beneficial owners must be reported. “As this new CTA rule now in effect pertains to individuals, a trust itself is not a beneficial owner.

Who are the beneficial owners of a charitable trust?

Who is a “beneficial owner”? The “beneficial owners” are the natural persons who ultimately own or control the trust and/or the natural persons on whose behalf a transaction or activity is being conducted. For a trust, the beneficial owners include: The settlor.

Who owns the assets held in a trust?

To find out who owns the assets in a revocable trust, look to whoever is the trustee. If the trustee is also the grantor, then the grantor still owns and controls the assets. If the grantor assigned another person or entity as the trustee, the trust owns the assets, which are managed by the trustee.

Who determines who holds the trust funds?

First, the grantor works with an attorney who writes the trust document based on the grantor's wishes for the distribution of specific assets. The grantor then chooses a responsible individual or firm to serve as trustee — holding and administering the assets for the benefit of the beneficiary.