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I decided before the deep dive to stop ignoring a failure of my computer to load the 24H2 update for Windows 11. Ended up spending five hours with support--Microsoft eventually decided to reinstall Windows 11 on my 'puter. So glad it's not tax season--feeling better about going forward now, especially with the help here. Thanks.

https://www.journalofaccountancy.com/news/2024/dec/nationwide-injunction-halts-boi-reporting-for-now.html "The AICPA understands the confusion and anxiety that business owners have struggled with regarding the BOI reporting requirement. We believe that the injunction … is applicable nationwide to all small businesses. While we are still awaiting formal guidance from FinCEN, if this injunction is applicable as we believe, many small businesses would receive the much-needed BOI reporting relief. The AICPA will continue an open dialogue with FinCEN in the hopes that our questions and concerns will be addressed, and we will continue to advocate on behalf of small businesses for clarity and relief."

On December 3, 2024, in deciding the case Texas Top Cop Shop, Inc., et al. v. Garland, et al., the U.S. District Court for the Eastern District of Texas found the Corporate Transparency Act (CTA) to be unconstitutional. The Court granted a nationwide preliminary injunction against the U.S. Department of Treasury Financial Crimes Enforcement Network (FinCEN), at least temporarily blocking it from enforcing the provisions of the CTA, which requires certain businesses to report beneficial ownership information (BOI) to FinCEN. This is potentially good news for many businesses, as the January 1, 2025, deadline to file initial BOI reports with FinCEN was quickly approaching. However, on December 4, 2024, FinCEN issued the following statement: The Corporate Transparency Act (CTA) plays a vital role in protecting the U.S. financial system, as well as people across the country, from illicit finance threats like terrorist financing, drug trafficking, and money laundering. We continue to believe—consistent with the conclusions of other federal courts—that the CTA is constitutional. Yesterday’s ruling is one of several cases pending before courts around the country, including ones in which district courts have denied requests to enjoin the CTA and that are now before courts of appeals. We are reviewing the ruling to determine our next steps. We would refer you to DOJ for any further information about the case. We believe that in light of the preliminary injunction, filing a BOI report now is technically not required, but we expect that the injunction will eventually be lifted and that filing will, at some point, be required. As FinCEN determines whether it will appeal the Court’s ruling in this case (and we wait to see if an appellate court will review the Court’s decision prior to the January 1, 2025 initial reporting deadline), we are advising our clients that are not eligible for an exemption under the CTA to delay submitting their BOI to FinCEN at this time but to continue to gather their BOI in order to be in a position to submit their BOI by January 1, 2025, in the event the ruling is overturned or stayed. We will keep a close eye on this decision as it works its way through the judicial system and update you immediately if our guidance changes. https://www.jdsupra.com/legalnews/important-update-temporary-halt-on-7521695/

A legal firm I trust posted (paraphrasing), those that have not filed, need not. If ever enforced, there will likely be a reasonable time to comply. Those that have already submitted, can do nothing, or consider trying to remove any data they deem sensitive. They mentioned the injunction was worded that it is likely the plaintiffs will prevail, but one must be prepared just in case. Logically, not that it applies, it may end up where the states will have to compel more data for company registration. To me, the principle is good, ability to know who is responsible. The flaw is the feds appear to be overstepping. I have privacy concerns, but there are very legal means to comply without giving away one's home address.

From AICPA: An AICPA statement acknowledged the potential effects of the injunction and urged CPAs assisting clients with BOI reporting to be prepared. “Under the injunction, FinCEN is barred from enforcing BOI filing requirements while the case is pending,” the statement said. “Best practices dictate that at a minimum those assisting clients with BOI report filings gather the required information from the clients and are prepared to file the BOI report if the injunction is lifted. While it is unlikely that the injunction will be lifted prior to the final outcome of the proceedings, we advise being prepared in the event that there is a reversal.”

@jklcpa Did it this morning. No issues. Different cell phone than the desktop. Tom Longview, TX

Tom, we got it figured out with Google auth. Works fine. Problem: We each have a copy of the program installed on two different computers. We are each admin on one computer. My authenticator code will not let me into her program, or her into mine. I intend to do a third as well. HELP!!!!

Create another user and setup MFA for each. That is what I have done for me and my wife. I think default is 3 users. If not there is room for one user besides Admin. i used Microsoft authenticator. Setup is easy.. download MS authenticator. click on + sign click other and scan QR code. Devm

Why ooh why would you delete data? I get it, some of us, especially longer in the tooth, try to save drive space. The days of tiny drives and drive space issues are decades ago gone. Deleting for security reasons? Sure, but if security is a concern, then an overall solution is likely better. Deleting to rid a computer? Indeed, there are tools for wiping drives, but I prefer to physically destroy them. With the above said, even today, a customer asked me how to delete data. I do not offer such a function, as within a few minutes of offering one, someone would be asking how to undo, or if I had a copy of their now deleted data I can give to them. If replacing computer/drives on a regular basis, restoring from backups, your machine would likely not have any old data on it (passed the retention timeline). For my software, I strongly remind to make monthly backups, offer free secure online backup storage, and have TWO separate on local drive locations for alternate data. One alternate location is easily found by the user and is saved every program close. This is a good one to use if there is a power outage. I also create what I call a "rescue" backup, stored in a location which likely will help when a computer "expert" helps out a customer and deletes their live data. It is also in a location which Windows backup includes, by default, as another means to help those who do not backup well, or at all. While I am all for the what you are not required to have cannot be used against you, as a software dev, zero harm to me comes from not offering any sort of mass delete function, and much harm can come to me - even if only being blamed for not preventing silly human error - if I were to offer such an option. Another example. A customer is currently trying to blame me for their issue of incorrectly moving/copying files. They are trying to blame me for commands they use outside of my software. The issue is their method has caused the deletion or remove of one of their data files, and they are insisting the software caused it, even though I have actual hard proof they caused the issue. This is a total waste of time, and I only can lose a customer and reputation, even though I did nothing wrong. And this is for something I do not even offer... so there is no way in you know what I will ever build in a function to delete unused data.

@mcb39 See what Judy says above. You will need to create a new login for the other machine with Admin Privileges for yourself. Then you will be able to pair your phone to her machine. You will login under the new user name. She will have to do the same for your machine. Tom Longview, TX

For someone who uses Drake, Judy has a lot of knowledge about ATX. Thank goodness. She should have written the instructions for ATX. Tom Longview, TX

Like Tom, I wonder how FinCEN is going to handle this. If you're on their notification list you know that they did send an email this afternoon, but it was a puff piece about nominations to the Bank Secrecy Act Advisory Group. Not that this wasn't important, but the communication failed to address the main thing that's on everyone's mind. I took a peek at their news site and there was no mention of this court case there either.

@mcb39 Are you still struggling with this? Do you need some help? I got through it and it was not as bad as I thought. Let me know if you need help. Tom Longview, TX

Supposed to be nationwide. However, very confusing since the judge in Alabama said he couldn't expand to everyone and this Texas judge says he can. They are both in the same federal circuit (5th?) so very different rulings. I expect Fincen to come out with a statement that they are appealing and that they expect taxpayers to comply with their rules during the legal process. Tom Longview, TX

Done and in. Not so bad. Tom Longview, TX

I use MS Authenticator and have zero issues with it. I use it both on my desktop as well as my laptop using Drake with zero issues. I have it set up for the Admin as well as my own personal log in. Once you get use to it, it really isn't that difficulty just a bit annoying!

Probably what Judy said. I seem to be able to use BitWarden as my IT guy set it up/scanned the QR code for prior year software up through 2023. Perhaps I'll need to scan a new QR code when I download 2024 (which I didn't want to do yet until I was able to use this new authentication thing for the rest of my late 2023 returns). Or, 1 January 2025. Or,... Glad I have my IT guy on retainer!

ProSystem fx (also WK) has a list of recommended authenticators that are supposed to work with my software. I started with the WK Authenticator, thinking it would be the most efficient with WK software. Not. Tech Support couldn't get me working. Techie liked the MS Authenticator, so I downloaded that. Support moved me up to the next tier. Still locked out of my very expensive software. Third tier support was supposed to call me. I called in my IT guy. He likes BitWarden. Got me running in minutes. (He took the other two authenticators off my phone.) I can finally get into my software, prior years too. Don't know why they have to make it so hard for us old ladies who grew up long before PCs and smart phones! I know it's NOT hard for the hackers.

It works and was easy to set up. I have everything set to automatically update, so I am not aware of how often that has happened. I haven't noticed anything odd with the phone, and that app has been on it for years now. Google's app does collect data though, so if that is an issue, maybe consider a different one. Article from PC Mag about the best of these apps for 2024 with pros and cons, on what devices they work best, and if they require an account. If you don't like the link, search for "best authenticator apps for 2024" and the article should be near the top of the list. https://www.pcmag.com/picks/the-best-authenticator-apps Some that are listed may or may not be recommended by your software.

Ahh, one last tip, yeah probably not. The clock on the computer or laptop where ATX is installed must be the same as the clock on mobile device where the authenticator is, otherwise the 30 second interval of expiration of the code won't be in sync.

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.