Nathan B. Hannah, attorney
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IRS TO IMPOSE REPORTING REQUIREMENT FOR ALL-CASH PURCHASES OF MILLION-DOLLAR + HOMES IN MIAMI AND NEW YOK CITY

1/15/2016

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It’s not entirely unexpected that the IRS would want to try to find out where the money is really coming from when a partnership, limited liability company, or trust pays more than a million dollars in cash for a house in Miami, or more than $3 million in New York City.  The announcement by the Financial Crimes Enforcement Network (“FinCEN”) of a requirement that title companies identify the natural persons behind such transactions is therefore not exactly a bombshell.
It does make me wonder, however, if the IRS is really just not trying all that hard to track down that information for itself, or if the disclosure rules are substantially different in states other than Arizona.  In Arizona, there are disclosure requirements for trusts, and public records filings for partnerships and limited liability companies, that make it pretty easy to find out, at least in most cases, who the real people are behind those big house purchases.  The newspaper in Phoenix publishes a regular column on big-dollar home transactions that includes the names of the real people even when they use trusts or business entities, which tells me that the reporter who writes that column knows how to look up that information.  Doesn’t the IRS?
Via TaxProf Blog.
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