2 Comments
author

I totally agree. The IRS has the information on 99% of these clients. It is likely the single member LLCs that should be filing these reports with FinCen or have the IRS require reporting this information when the applicable return is filed. It would be very easy to report it that way but that is too logical.

Expand full comment

This is an interesting question. CPAs have been assisting in preparing FBARs, which are filed with FinCEN. For 99% of the CTA reports, there shouldn’t be any complexity; the reports could be completed by the client. Perhaps the CPAs services can be a reminder to the client: “Did you complete your CTA report?” It’s so ridiculous, considering that most businesses are owned by individuals. Annual tax filings could simply add the newly required information to the tax return, and let IRS transmit the information to FinCEN.

Expand full comment