Congress passed a sweeping new law that will affect most businesses in the United States in 2024. The Financial Crimes Enforcement Network (FINCEN) will be the Federal Agency administering this new law. This sweeping new law was passed to fight money laundering.
You will fill out our tax planner before we do your personal income taxes. This new reporting regime is such a big deal it is the first question on our tax planner this year. “Are you an owner of an LLC or Corporation?” It is extremely important that you fill this out correctly and give us a list of all companies that you own, and all companies owned by anyone listed on your personal income tax returns.
The new rules are complicated and will require businesses to file new initial reports with the Financial Crimes Network and to further update those reports in certain circumstances.
This is something we will discuss when we finish your 2023 income tax returns in 2024. This is a big deal and the penalties for non-compliance are a fine of up to $10,000 and up to two years in jail.
All of our clients will have to sign and date a separate engagement letter for each business they own. Due to the seriousness of the fines and jail sentences; all of our clients will either sign and date the engagement letter hiring us to file the initial report OR our clients will sign and date an engagement letter certifying they will handle the report or hire a third party, such as an attorney, to file these reports for them. Further, we will only file these reports for Indiana companies, and we will either handle both the Indiana Secretary of State entity renewals and the FINCEN BOI reports, or we will handle neither.
SBS CPA Group has been open for over 22 years and this is the first time we are going to have our clients sign an engagement letter opting into us providing an add-on service or opting out of SBS CPA Group providing this service for you. These new laws are a very big deal, and the initial reports will require valid photo identification to be uploaded to the FINCEN website for certain owners and a few managers of certain companies.
The engagement letter is a full three pages long and has a lot of very important information that business owners will need to understand. When you come in to pick up your income taxes, please set aside the time needed to read this engagement letter!
We will NOT be filing FINCEN reports until after tax season. Instead, we are collecting engagement letters from our clients, and we will deal with this after tax season is over! We do not have time to deal with new programs like this during our busiest time of the year!
The Federal Government expects 32.6 million initial reports to be filed in 2024 and projects that it will take businesses owners and the professionals they rely on well over 119 million hours in 2024 to deal with these far-reaching new requirements.
Many accounting firms and some attorneys will not be filing these reports for their clients. We plan on providing this service based on the current rules.
Mike Sylvester, CPA
SBS CPA Group promises to execute an amazing customer experience through service and communication. We guarantee to make sure your needs are met. Questions about our services are welcome and encouraged!
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