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One other interesting (and scary) part of the discussion was third-party filing services. Some of course are reliable, well-known online companies with long histories in the online space. But there are also some shady players out there who are using the filing requirement to simply compile the information and then not even bother to complete the filing. The client winds up with stolen data and also being in non-compliance. And be careful about recommending that the client use a third party online service. Especially if their fee seems unusually low when compared to industry standard.

This is an interesting idea. Thanks for sharing it. But I’m not inclined to advise the HOA on something not clearly stated by FinCEN in their FAQ’s as acceptable. Too many risks if the advice is later found to be wrong, and not enough time before Dec 31, 2024 to thoroughly consider it. Incidentally, the presenter said current estimated compliance by state ranges between 6% and 24%, as I recall. That could mean the system is going to get overloaded and slow down to a crawl or even seize up in the coming weeks. He also raised some troubling scenarios if IRS puts a question on the tax return 2-3 years from now (similar to the Foreign Accounts question on Schedule B. Might create some problems for tax preparers who had not documented that they advised their clients of the requirement this year.

With respect to HOA’s, the issue isn’t ownership. The issue is whether the HOA is registered with the Secretary of State. If so, then the HOA must file.

I highly recommend keeping a backup of the data files, just in case. The default location of the complete ATX database is: C:\ProgramData\Wolters Kluwer Unless you changed the default locations. The folder is called ATX 2018 Server. If you have client folders with PDFs of tax returns and records, those will be wherever you chose to put them.

I was in an Update Webinar yesterday and they discussed FinCen Identifiers. Apparently, you can shift the burden of updating information off of the organization and onto the individual if the individual gets a FinCen Identifier. 2 uses of this Identifier. 1. Person has multiple organizations that they need to be reported for. Individual gets an Identifier from Fincen and only has to give the number to each entity. 2. Entity does not want to keep up with the changes of all individuals. Requires each individual to get an Identifier and the individuals are required to update their personal information when it changes and the entity only reports changes in individuals who are added or removed from the company. The presenter thought that there would be a movement to make all persons agree to get an identifier from FinCen so the responsibility for updates shifts from the entity to the individual (as well as the fines for non-compliance). @JohnH you may want to explore this idea with your HOA. Tom Longview, TX