As I understand it, if the injunction is eventually overturned and the BOI requirements are upheld, FinCEN would likely establish new compliance deadlines rather than trying to enforce the original ones retroactively. It would be pretty unreasonable to penalize businesses for non-compliance during a period when a court order explicitly stated they didn't have to comply. The penalties are indeed significant - civil penalties of $500 per day for violations, plus potential criminal penalties including imprisonment for willful violations. But these would only apply to violations of whatever new deadlines might be established if the CTA is ultimately upheld.

That makes sense, thanks for the clarification! I was worried we might get caught in some kind of legal trap if we don't file now but then the requirements come back later. I'll just keep our information ready but hold off on filing until there's more clarity.

I think your accountant is being overly cautious. While FinCEN's system remains operational and you technically *can* still file, there's no legal requirement to do so while the injunction is in effect. There's no penalty for not filing right now. Unless you have some very specific business reason for wanting your beneficial ownership information on file with the government during this period of uncertainty, I'd recommend waiting to see how the legal situation resolves. Just keep your information organized so you're ready if/when the requirement comes back.

But what if their parents added them as an authorized user on their HSA? Couldn't they contribute that way since it's still part of the family limit?

Being an authorized user on someone else's HSA is different from having your own HSA eligibility. Authorized users can withdraw funds from someone else's HSA for qualified medical expenses, but they don't gain contribution rights. HSA contribution eligibility is tied to having your own HDHP coverage. Being covered as a dependent on someone else's family plan doesn't make you eligible to contribute to any HSA, either yours or theirs. The family contribution limit belongs to the HSA account owner (the parents in this case), not to the dependents covered under their plan.

You've got the testing period concept right but the year wrong. The "last-month rule" would only help for 2023 contributions if OP had their own HSA-eligible coverage by December 1, 2023 (which they didn't). Since they only got their own HDHP coverage in January 2024, the last-month rule might apply to their 2024 contributions (if they maintain coverage through Dec 31, 2024), but it can't retroactively create eligibility for 2023.

That's actually a really thoughtful suggestion. We do give to our church and a couple local charities already, but hadn't thought about the tax angle. Would bunching donations in alternating years work better to get over the standard deduction threshold?

Yes, bunching donations is exactly what many financial planners recommend! For example, if you normally donate $5,000 per year, you could instead donate $10,000 every other year. This might push you over the standard deduction threshold in donation years (when you itemize) while taking the standard deduction in off years. Another option is a Donor Advised Fund, where you contribute a larger amount in one year for the tax deduction, but distribute the actual donations to charities over multiple years. This gives you the tax benefit immediately while allowing you to support charities gradually.

Yeah but the standard deduction for 2025 filing season is projected to be over $29,000 for married couples! Makes it even harder to benefit from mortgage interest unless you have a jumbo loan.

This is really helpful! We do track who's playing but never thought to separate member vs. guest gaming income. Do we need to track that separately on our books? And does it matter if the guests are paying the members who brought them, or paying directly?

Yes, you should definitely track member vs. non-member income separately in your books. This makes it much easier if you ever get audited, and helps with completing your 990 accurately. The IRS specifically looks at this breakdown for veterans' organizations. For your second question, it matters who's actually putting the money in. If the guests are paying directly for their own gaming activities, that's considered non-member income. If members are paying on behalf of their guests, that could be considered member income. The safest approach is to consider all guest payments as non-member income and track it that way. Better to be conservative with this.

Yes, we file 990-T for a portion of our gaming income. You can deduct directly connected expenses - so for pull tabs, that includes the cost of the pull tabs themselves, any specific equipment for them, allocated space costs for the area where they're sold, and the portion of that paid employee's time spent on pull tabs. Just make sure you have a reasonable allocation method that you apply consistently.

Thanks for explaining! That makes sense about the direct expenses. Do we need to keep separate physical inventories of the pull tabs as well or just track it in our accounting system?

This is great info! Does anyone know if there's a way to tell from the K-1 whether the trust is a grantor trust? I think mine might be because my grandfather is still alive and the letter mentions something about him being the "grantor" but I'm not sure if that changes how I report it.

A grantor trust is actually quite different for tax purposes. If you see your grandfather referred to as the "grantor" and he's still alive, it might indeed be a grantor trust. In that case, the income is actually taxable to the grantor (your grandfather), not to you as the beneficiary. However, some trusts can be partially grantor trusts. The key indicator on your K-1 would be in the top section - it should specifically identify if it's a grantor type trust by checking a box. If you received a K-1 with your name as the beneficiary, you likely still need to report something, but possibly not all items. The cover letter should clarify this, as grantor trusts have special reporting requirements.

Ugh that's what I was afraid of. Do you know if there's a minimum amount that requires amending? Mine is only showing like $800 in dividend income. Would the IRS even notice if I don't bother with an amendment for such a small amount?

Thanks everyone for all the helpful answers! I'm going to make sure I report everything correctly from my K-1. Seems like the consensus is that I need to include the information on my tax return but don't physically send in the K-1 form itself. I'll keep the original documents with my tax records just in case. I'll probably check out that tax document analyzer tool too since this is my first time dealing with trust income. Better to understand what I'm looking at rather than just blindly entering numbers into tax software!