FinCEN BOIR

[Randall]

Anyone dealing with this yet?  Just opening it up for discussion.  Seems outlandish but then what else is new?

[Lloyd Hudson]

I had a couple of inquiries pertaining to the BOI, but had NO bearing on tax prep. I refer them to ficen.gov. Only answer I have. I gave up babysitting adults when I passed  80. I was talking to my brother about this sort of thing , he just commented that most of our clients and/or friends have less than half of OUR COMBINED experience. 160 years

He maintains that I should not expect them to have what I would consider common sense. 

Crabby old man 

 

 

[michaelmars]

We are their trusted advisors and even if you are not going to file these for your clients you should still be up on the requirements and be prepared to offer them some advice besides referring them to a government website.  There are many accounting groups putting out 1-2 page summaries, in simple plain language for you to send to clients.  

If you are willing to take this on, it could be a huge money maker for during out slow summer time.  We are offering to do the first, initial filing but will not be doing any monthly monitoring.

Every accounting group and E&O company is saying to make sure your engagement letters explicitly state that your tax work will not include BOI filings but advise them to educate themselves as to the requirements.  Our separate BOI engagement letter will be a few pages long too.

[Medlin Software, Dennis]

Sounds like a win win service.  As I still believe once or twice a year revisit of W4 and withheld amounts would be. When I read about large returns or balance due, I read it as missed opportunity to provide a profitable service. Not only on its face, but to likely improve/ensure retention. Unless the customer believes a refund is favorable to them.

[Lee B]

I will file my own BOI and no more. I will give them a letter so that they are aware of the requirements supported by several pages with more detail.

I am not going to answer questions or offer advice. If they have questions or need advice I will refer them to seek out a knowledgeable attorney.

FINCEN BOI has nothing to do with accounting, tax law or tax returns.

It is  not administered by the IRS and our privileges and responsibilities under Circular 230 do not apply.

 

[Catherine]

We put the requirement to file in the engagement letter, more clearly than past years' one-sentence fbar notice. But we won't do them (nor the fbar; just the 8938s). Preparer penalties can be vicious on anything to do with foreign reporting. I have my areas of specialty, and this ain't one of them.

[BulldogTom]

I sent my clients who were subject to the reporting the FinCen guide last fall.   I think that guide is well written and clearly explains the process.   I told my clients I was providing the guide as a courtesy but I would not be filing for them.   I have answered a couple of questions about when to file (my advice, this is an election year and some people are upset by this perceived government overreach - so wait till after the elections to see if anything changes in the law).   That is as far as I have gone with advice on the situation.

Tom
Longview, TX

[Randall]

16 hours ago, BulldogTom said:

I sent my clients who were subject to the reporting the FinCen guide last fall.   I think that guide is well written and clearly explains the process.   I told my clients I was providing the guide as a courtesy but I would not be filing for them.   I have answered a couple of questions about when to file (my advice, this is an election year and some people are upset by this perceived government overreach - so wait till after the elections to see if anything changes in the law).   That is as far as I have gone with advice on the situation.

Tom
Longview, TX

The only problem with this being an election year is that the election is in November and if one party wins all, they won't be able to do anything until January, 2025, after the due date of Jan 1, 2025.

[BulldogTom]

1 hour ago, Randall said:

The only problem with this being an election year is that the election is in November and if one party wins all, they won't be able to do anything until January, 2025, after the due date of Jan 1, 2025.

My point is that when the idiots leave the beltway to campaign and hear that this is a problem, they may try and get something done before the election to win votes before people go to the ballot box.

Tom
Longview, TX

[Lee B]

Back in December the House passed a bill 420 - 1 to delay the implementation by one year.

The Senate has yet to vote on this bill.