美國財政部發布的《企業透明法》新指南明確規定，該法案規定的受益所有人始終是自然人，中間公司無需報告為受益所有人。 它明確規定信託、公司和法人實體不構成受益所有人。 報告公司僅在有限的情況下才可以將公司受託人認定為受益所有人。

COMPLIANCE: Intermediate entities do not need to be reported as beneficial owners, says US treasury

New guidance on the Corporate Transparency Act issued by the US Department of the Treasury clarifies that a beneficial owner under the Act will always be a natural person and that intermediate entities do not need to be reported as beneficial owners. It explicitly states that trusts, corporations and legal entities do not constitute beneficial owners. A reporting company may identify a corporate trustee as a beneficial owner only in limited circumstances.

Sources:
Bryan Cave Leighton Paisner
Financial Crimes Enforcement Network (FinCEN)
Duane Morris
Benesch, Friedlander, Coplan & Aronoff
FinCEN (updated appeal notice, PDF)