Category Archives: FINCEN

Corporate Transparency Act Ruled Unconstitutional; Appeal Certain

On Friday, an Alabama federal judge ruled that the Corporate Transparency Act (CTA)–the law that authorized Beneficial Ownership Information (BOI) reporting–is unconstitutional.  As of today, this decision impacts one business in northern Alabama, but given an appeal is a certainty … Continue reading

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Online Gambling and Cryptocurrency Addresses for 2024

This list has been replaced by the 2025 List. If you have one or more foreign financial accounts and you have $10,000 aggregate in those account(s) at any time during 2023, you must file the Report of Foreign Bank and … Continue reading

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IRS Officially Announces Delay in Reporting Cryptocurrency Transactions on Form 8300

The IRS officially announced today that businesses do not have to report the receipt of digital assets on Form 8300 until the Treasury and the IRS issue regulations implementing the new law.  The IRS officially announced this in Announcement 2024-4.  … Continue reading

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Form 8300 and Cryptocurrency: Implementation Postponed

The IRS sent emails to two tax professionals regarding Form 8300 and cryptocurrency: Treasury has postponed the effective day of 12/31/2023 for filing 8300 forms regarding digital asset transactions (Cryptocurrency). The updated [form] as well as guidance on electronic filing … Continue reading

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Form 8300, Cryptocurrency, and Gambling: An Update

Last August I wrote a post noting that as of January 1, 2024 cryptocurrency is considered to be cash for Form 8300 reporting requirements.  Here’s what I wrote last August: A Twitter/X post from John Reed Stark reminded me about … Continue reading

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The Upcoming Beneficial Ownership Information Disaster

Is the light on the horizon the end of the long tunnel you’re transiting or the oncoming train?  Unfortunately, I see an oncoming train on the horizon in the new mandatory Beneficial Ownership Information reporting.  If you’re a business owner … Continue reading

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FBAR Non-Willful Penalty Is Per Report, Not Per Account

Let’s assume you have a non-willful violation of filing the FBAR (Form 114, the Report of Foreign Bank and Financial Accounts).  Is the maximum penalty ($10,000) per account or per report?  The Circuit Courts of Appeal had split on this … Continue reading

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FINCEN Gives FBAR Filing Relief for Individuals Impacted by Hurricane Ian

FINCEN announced today that they are following the IRS and giving relief to taxpayers impacted by Hurricane Ian: FinCEN announced today that victims of Hurricane Fiona in Puerto Rico; Hurricane Ian in Florida, North Carolina, and South Carolina; and storms … Continue reading

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On Exchanging Cryptocurrency for Casino Chips (or Cash)

The high stakes poker world works a little differently than you might think.  Most of the players frequenting these games know each other, and borrowing money from one another is common.  Another common occurrence is the exchanging of cryptocurrency for … Continue reading

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Square Pegs and Round Holes: Tornado Cash, Anti-Money Laundering, and Crypto

On August 8th, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) went after virtual currency “mixer” Tornado Cash.  Tornado Cash was sanctioned, and as the Treasury’s press release notes, As a result of today’s action, all … Continue reading

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