08 September 2025
Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is reissuing a modified Geographic Targeting Order (GTO) to combat illicit cartel and other criminal activity, including money laundering, along the southwest border of the United States. As modified, the GTO requires certain money services businesses to file Currency Transaction Reports with FinCEN for cash transactions between $1,000 and $10,000 occurring in specific counties and ZIP codes. The terms of this GTO are effective September 10, 2025, through March 6, 2026.

News Release: https://www.fincen.gov/news/news-releases/fincen-issues-modified-southwest-border-geographic-targeting-order

Copy of the GTO: https://www.fincen.gov/system/files/2025-09/September-2025-SWB-GTO-Order-FINAL-508C.pdf

Frequently Asked Questions: https://www.fincen.gov/system/files/2025-09/FAQs-FINAL-508C.pdf

DRAFT 2026 FORM W-2 INCLUDES BOES & CODES FOR TIPS & OVERTIME!!

 

A draft version of Form W-2, Wage and Tax Statement, for 2026 includes boxes and codes for reporting qualified tips and qualified overtime compensation that can be deducted temporarily under the provisions of H.R. 1, P.L. 119-21, commonly known as the One Big Beautiful Bill Act.  For more information,see the file labeld 2026 draft w2

The AICPA has become aware of the following from members’ communication and have passed this information on to the Internal Revenue Service:

IRS CP504B erroneous intent to levy and CP161 erroneous notices to trusts on Form 1041, individuals on Form 1040 and corporations on Form 1120 on correctly paid estimated payments based on 100% of prior year liability

For more information, see the file labeled Erroneous IRS Notices Update. 

Issuance of a Geographic Targeting Order Imposing Additional Recordkeeping and Reporting Requirements on Certain Money Services Businesses Along the Southwest Border

FinCEN is issuing notice of a Geographic Targeting Order, requiring certain money services businesses along the southwest border of the United States to report and retain records of transactions in currency of more than $200 but not more than $10,000, and to verify the identity of persons presenting such transactions.

For more information:  https://www.federalregister.gov/documents/2025/03/14/2025-04099/issuance-of-a-geographic-targeting-order-imposing-additional-recordkeeping-and-reporting

FAQs Released for FinCEN Geographic Targeting Order Impacting California and Texas Border Region Money Services Businesses

The GTO dramatically lowered the Currency Transaction Report (CTR) threshold to just $200 for MSBs operating in specific ZIP codes along the southwest border. This represents a substantial change from the standard $10,000 CTR reporting requirement that most financial institutions follow.

 

For tax professionals in the affected zip codes, this order specifically impacts clients operating in:

1. Imperial County, California: 92231, 92249, 92281, 92283;
2. San Diego County California: 91910, 92101, 92113, 92117, 92126, 92154, 92173;
3. Cameron County, Texas: 78520, 78521;
4. El Paso County, Texas: 79901, 79902, 79903, 79905, 79907, 79935;
5. Hidalgo County, Texas: 78503, 78557, 78572, 78577, 78596;
6. Maverick County, Texas: 78852; and
7. Webb County, Texas: 78040, 78041, 78043, 78045, 78046.

The Following Types Of Businesses Are Likely To Be Affected:

 

 Money Services Businesses (MSBs) specifically mentioned in the order:

• Currency exchangers/money exchangers
• Check cashers
• Money transfer businesses (like Western Union, MoneyGram)
• Money order issuers and sellers
• Prepaid access providers and sellers

Other financial service providers in the affected ZIP codes:

• Convenience stores offering money transfer services
• Grocery stores with check cashing or money order
• services
• Small independent financial service providers
• obile payment service providers with cash-in/cash-out capabilities

Tax professionals with clients in the affected areas should immediately begin preparing for implementation. The drastically lower reporting threshold will likely result in a significant increase in filing requirements for MSBs in these regions. Questions about the GTO should be directed to FinCEN through their website.

Executive Order Mandating Electronic Federal Tax Refunds and Payments for Taxes

Beginning as early as September 30, 2025, the president’s March 25, 2025, executive order “Modernizing Payments To and From America’s Bank Account”  mandates all payments to and from the US Treasury be paid electronically. This includes federal tax payments and federal tax refunds.

Here is the link to the Executive Order 

BOI filing requirements for US companies and persons removed, new deadlines set for foreign companies 03/21/2025

ALERT [Updated March 26, 2025]: All entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners are now exempt from the requirement to report beneficial ownership information to FinCEN. Existing foreign companies that must report their beneficial ownership information have at least an additional 30 days from March 26, 2025—until April 25, 2025, for most companies—to do so. For more information, see press release and alert.

Financial Crimes Enforcement Network BOI FAQ 

IRS announces Hiring Freeze

The IRS has rescinded all job offers with a start date after Feb. 8 or with an unconfirmed start date because of a hiring freeze ordered by President Donald Trump, the agency said on its website.

Due to the Executive Order signed by the President on January 20, 2025, the Federal government has been placed on a hiring freeze. For your convenience, the link to the official White House communication related to the Federal Hiring Freeze is contained here: https://www.whitehouse.gov/presidential-actions/2025/01/hiring-freeze/.

All offers with a start date on or before Feb. 8 will continue or proceed with the hiring according to a post on the IRS jobs website. Meanwhile, the IRS said it will remove all jobs posted to external websites, including USAJOBS.gov.

Federal Civilian Hiring Freeze Guidance

IRS announces 2025 tax filing season and Direct File availability

The IRS will begin accepting business returns at 8 a.m. CST January 15 and individual returns at 8 a.m. CST starting January 27

Beneficial Ownership Information Reporting

Updates to Beneficial Ownership Information Reporting Deadlines – Beneficial Ownership Information Reporting Requirements are not currently required

Alert:  Alert [December 27, 2024]: Impact of Ongoing Litigation – Deadline Stay – Voluntary Submission Only

In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports. More information is available on our website.

In light of a December 23, 2024, federal Court of Appeals decision, reporting companies, except as indicated below, are once again required to file beneficial ownership information with FinCEN. However, because the Department of the Treasury recognizes that reporting companies may need additional time to comply given the period when the preliminary injunction had been in effect, we have extended the reporting deadline.

BOI Extension information

At approximately 5:30 pm CST Tuesday, 03 December 2024, Judge Amos L. Mazzant III of the US District Court for the Eastern District of Texas issued an injunction preliminary blocking the regulations nationwide.  The AICPA on Thursday, December 5, 2024, sent their CPA Letter with the Top Story headlines of this news.

Federal ruling halts BOI reporting for now

Finding the Corporate Transparency Act “likely unconstitutional,” a federal district court prohibited its enforcement and the enforcement of its accompanying regulations. Journal of Accountancy (12/5)

Other reports regarding the ruling are available in the links below.

Bloomberg Law  The Woodard Report

IRS to Use IP PINs to Stop Refund Delays Due to Duplicate Dependent Returns

The IRS will begin accepting certain e-filed tax returns claiming dependents who have already been claimed on another taxpayer's return to prevent refund delays for tax credits, including the earned income tax credit (EIC) and the child tax credit (CTC). Beginning with the 2025 filing season, the IRS will accept Forms 1040, 1040-NR and 1040-SS, even if a dependent listed on the return has been claimed on someone else's previously filed return, so long as the primary taxpayer on the second return includes a valid identity protection personal identification number (IP PIN).

More information

FinCEN Publishes Beneficial Ownership Reporting Outreach and Education Toolkit

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued another resource to familiarize small business owners with beneficial ownership reporting requirements. These reporting requirements are mandated by the Corporate Transparency Act, a bipartisan law enacted to curb illicit finance by supporting law enforcement efforts. This law requires many small businesses to report basic information to the Federal government about the real people who ultimately own or control them.

The toolkit contains templates and sample content that has been structured to allow private, public, and non-profit organizations to share and amplify this important information. The toolkit includes general background on the reporting requirements, as well as templates for newsletters, websites, and emails; sample social media posts and images; and information on how to contact FinCEN.

News Release: https://www.fincen.gov/news/news-releases/fincen-publishes-beneficial-ownership-reporting-outreach-and-education-toolkit

Toolkit: https://www.fincen.gov/boi/toolkit

Chevron doctrine overturned: Implications for tax professionals

In this joint episode, Neil Amato, host of the Journal of Accountancy podcast and Melanie Lauridsen, VP of AICPA Tax Policy and Advocacy discuss two recent Supreme Court decisions.

The Supreme Court ruling in Loper Bright Enterprises v. Raimondo overturned a 40-year-old precedent of deference referred to as the Chevron doctrine, affecting future rulemaking by eliminating the need for judges to defer to agency interpretations of ambiguous statutes. In Corner Post, Inc. v. Board of Governors of the Federal Reserve System, the Supreme Court ruled to alter the statute of limitations for challenging regulations, starting the clock when a plaintiff is injured rather than when the regulation is enforced.

 

These decisions introduce significant uncertainty for the accounting profession, particularly regarding IRS regulations and long-standing rules and emphasize the need for CPAs to stay informed and adaptable as the implications of these rulings unfold.
Tax Section 

Final and proposed regulations issued on retirement plan RMDs

Please see the July 18, 2024, article in the Journal of Accountancy

IRS Statement on balance due notices (CP14)

June 12, 2024

The IRS is aware that some taxpayers are receiving CP14 (Balance Due, No Math Error) notices indicating a balance due even though payments were made with their 2023 tax return.

Who is affected: Taxpayers who paid electronically or by check with their 2023 tax return, may show their accounts as pending, although the IRS has received and processed payment through their banking institution. The notice may have been initiated before the payment was processed on the account, or the payment may have been processed but contained errors and requires additional handling to address the error before updating the tax account.

No immediate action or phone call needed: Taxpayers who receive a notice but paid the tax they owed in full and on time, electronically or by check, should not respond to the notice at this time. The IRS is researching the matter and will provide an update as soon as possible.

Note that any assessed penalties and interest will be automatically adjusted when the payment(s) are applied correctly by the IRS.

Taxpayers who paid only part of the tax reported due on their 2023 return should pay the remaining balance or follow instructions on the notice to enter into an installment agreement or request additional collection alternatives.

For affected taxpayers, the IRS apologizes for the inconvenience this delay in processing your payment has caused.