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Section of Guide
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Changes made
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Date Updated
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Various
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1. Corrected a number of minor typographical mistakes and inserted missing hyperlinks.
2. Addressed changes to 5 C.F.R. § 2635.503 due to the update of the Standards of Conduct.
3. Revised guidance to make it consistent between the parts.
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Nov 2024
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Part 2, Part 3, and Part 5: Health Savings Account (HSA)
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Added a new entry for Health Savings Account
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Nov 2024
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Part 6: Inherited IRA or Roth IRA
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Added a new entry for Inherited IRA or Roth IRA
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Nov 2024
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Various
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Corrected a number of minor typographical mistakes, which had already been corrected in the web version of the guide.
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Jan 2024
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Various
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Updated the names used in the reporting examples to reflect greater diversity. In addition, revised certain dates to make them more relevant for filers completing reports in 2022 and after.
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Jan 2024
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Part 2 and Part 5, Carried Interest
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Clarified that, in the rare case that a filer/spouse has carried interest on a fund that qualifies as an excepted investment fund, the underlying holdings of that fund do not need to be disclosed as part of the carried interest description.
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Jan 2024
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Part 2 and Part 5, Deferred Compensation
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Added an example of a deferred compensation plan that tracks a basket of stocks.
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Jan 2024
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Part 2 and Part 5, Government Benefit or Payment
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Clarified that, for purposes of financial disclosure, unemployment benefits are reportable for a filer but not for a spouse.
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Jan 2024
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Part 2 and Part 5, Intellectual Property
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Added note reminding filers of the difference between being difficult to value and having little value.
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Jan 2024
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Part 2, Part 3, and Part 5, Option or Warrant
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Expanded the existing incentive stock option plan entries to cover all employment-related options and warrants.
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Jan 2024
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Part 2, Part 3, and Part 5, Small Business (installment sale)
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Added a new entry for installment sales of a filer’s/spouse’s business.
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Jan 2024
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Part 2, Part 3, and Part 5, Small Business (third-party escrow agreement)
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Revised the existing third-party escrow agreement entries to focus on such agreements within the context of selling a filer’s/spouse’s business.
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Jan 2024
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Part 2 and Part 5, TIAA
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Added examples of TIAA products in a defined contribution plan and in an IRA.
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Jan 2024
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Part 4 and related pages
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Revised the sample language used for the non-disclosure of a confidential client.
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Jan 2024
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Part 6, Annuity (indexed)
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Added a new entry for indexed annuities.
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Jan 2024
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Part 6, Business Development Corporation (BDC)
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Added a new entry for equity in business development corporations.
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Jan 2024
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Part 6, Business Development Corporation (BDC) Bond/Note
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Added a new entry for debt issued by business development corporations.
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Jan 2024
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Part 6, College Savings Plan (529 plan)
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Added an example of a final distribution from a plan with no assets and reformatted the other examples for clarity.
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Jan 2024
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Part 6, Donor-Advised Fund
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Added a new entry for donor-advised funds.
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Jan 2024
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Part 6, Exchange-Traded Note (ETN)
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Added a new entry for exchange-traded notes.
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Jan 2024
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Part 6, Health Savings Account (HSA)
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Added a new entry for health savings accounts.
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Jan 2024
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Part 6, Investment Club
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Added a new entry for investment clubs.
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Jan 2024
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Part 6, Master Limited Partnership (MLP)
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Added a new entry for master limited partnerships.
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Jan 2024
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Part 6, Collectible Non-Fungible Token (NFT) or Fractionalized Non-Fungible Token (F-NFT)
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Added a new entry for collectible non-fungible tokens and fractionalized non-fungible tokens.
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Jan 2024
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Part 6, Option (put or call purchased)
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Added a discussion of index options.
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Jan 2024
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Part 6, Real Estate (installment sale)
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Added a new entry for installment sales related to the sale of real estate.
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Jan 2024
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Part 6, Real Estate Investment Trust (REIT)
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Added a new entry for real estate investment trusts, distinguishing them from other real estate holding companies.
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Jan 2024
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Part 6, Solar Renewable Energy Credit Agreement
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Added a new entry for solar renewable energy credits.
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Jan 2024
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Part 6, Special Purpose Acquisition Company (SPAC)
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Added a new entry for special purpose acquisition companies.
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Jan 2024
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Part 6, Virtual Currency (cryptocurrency or stablecoin)
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Revised the virtual currency entry to clarify terminology used for holding and trading virtual currency. Entry also revised to cover passive staking arrangements.
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Jan 2024
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Part 6, Warrant
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Added a new entry for warrants.
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Jan 2024
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Part 9 and various other pages
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Updated the reporting thresholds for gifts and travel reimbursements to reflect the regulatory change for gifts and travel reimbursements received after January 1, 2023.
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Jan 2024
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Part 9, Gifts and Travel Reimbursements
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Added an example for a gift accepted as a widely attended gathering.
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Jan 2024
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For Ethics Officials, 1.02: Individuals Required to File
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Added clarifying cross-reference to day-counting rules in the “Detailees” sub-section.
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Jan 2024
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For Ethics Officials, 1.04: Extensions
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Clarified the treatment of combat zone extensions, including a specific confirmation that the extension can apply to OGE Form 278-T reports.
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Jan 2024
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For Ethics Officials, 1.05: Late Filing Fees
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Clarified that late filing fees and late filing fee waivers must be documented in the filer’s report file but should also be noted on the report itself. In addition, added a discussion of when an agency may stay imposing a late filing fee.
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Jan 2024
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For Ethics Officials, 1.08: Collection of Termination Reports
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Added a discussion of how agencies might design a termination report collection process.
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Jan 2024
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For Ethics Officials, 2.02: Spouses and Dependent Children
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Added note clarifying that filers need not report alimony or child support.
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Jan 2024
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For Ethics Officials, 2.03: Cover Page of the OGE Form 278e
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Updated discussion of how Integrity treats intermediate reviewer signatures.
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Jan 2024
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For Ethics Officials, 2.06: Part 3
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Clarified reporting requirements to underscore that maintaining a defined contribution plan account constitutes “participation” in the plan.
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Jan 2024
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For Ethics Officials, 3.01: Cover Page of the OGE Form 278T
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Updated discussion of how Integrity treats intermediate reviewer signatures.
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Jan 2024
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For Ethics Officials, 4.01: Review Steps and Certification Requirements
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Added a summary of the basic steps in a review.
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Jan 2024
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For Ethics Officials, 4.07: Public Availability
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Provided additional guidance on a number of issues related to the release of public financial disclosure reports.
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Jan 2024
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For Ethics Officials, 4.09: Forwarding Reports to OGE
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Removed the reference to “acting” DAEOs.
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Jan 2024
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For Ethics Officials, 4.10: Special Procedures for Nominees
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Added a sample 5-day update letter.
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Jan 2024
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Definitions: Various
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Added definitions for new and revised main Guide entries.
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Jan 2024
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Definitions: Asset
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Provided additional guidance as to when items would be viewed as held for investment or the production of income.
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Jan 2024
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Definitions: Exchange
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Provided a general definition of when an exchange happens for purposes of financial disclosure.
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Jan 2024
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Definitions: Futures Contract
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Added a discussion of index futures.
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Jan 2024
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Definitions: Gift
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Added a definition of a gift.
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Jan 2024
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Definitions: Income Types
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Added a discussion of things excluded from income for purposes of financial disclosure.
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Jan 2024
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Definitions: Purchase
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Added a definition of when a purchase happens for purposes of financial disclosure.
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Jan 2024
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Definitions: Personal Residence
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Clarified that the term “personal residence” can include a residential property held for rent-free use by a family member.
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Jan 2024
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Definitions: Received
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Clarified that income deferred pursuant to a Certificate of Divestiture is still “received” during the reporting period of the sale for purposes of financial disclosure.
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Jan 2024
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Definitions: Sale
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Added a definition of when a sale happens for purposes of financial disclosure.
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Jan 2024
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Definitions: Security
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Clarified the definition of security for purposes of financial disclosure.
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Jan 2024
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Definitions: Travel Reimbursement
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Added a definition of a travel reimbursement.
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Jan 2024
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Definitions: Virtual Currency
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Clarified that the term “virtual currency” in the guide is meant to include cryptocurrency and stablecoins.
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Jan 2024
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FAQs: Bond (corporate)
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Added a FAQ for preferred securities (i.e., report as stock rather than as a bond).
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Jan 2024
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FAQs: Brokerage Account
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Added a FAQ reminding filers that dividends and capital gains in a taxable brokerage account are reportable as “received.”
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Jan 2024
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FAQs: Collectible Item
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Clarified explanation of when a collectible item is held for investment or the production of income.
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Jan 2024
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FAQs: College Savings Plan (529 plan)
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Added FAQs for 529 plans.
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Jan 2024
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FAQs: Defined Benefit Plan
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Added guidance for reporting unvested plan interests.
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Jan 2024
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FAQs: Honorarium
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Clarified when a speakers’ bureau must also be reported as part of the disclosure of honoraria. Added a FAQ addressing an honorarium from the U.S. Government.
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Jan 2024
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FAQs: Intellectual Property
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Added a FAQ for self-published books.
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Jan 2024
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FAQs: Law Firm (partnership)
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Added a FAQ for a capital account returned before the end of the reporting period.
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Jan 2024
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FAQs: Liabilities
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Added a FAQ for aggregate liabilities to a creditor in excess of $10,000 that are individually each less than $10,000. Also added a FAQ for refinanced mortgages.
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Jan 2024
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FAQs: Loan Made to Another Party
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Added a FAQ for peer-to-peer lending.
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Jan 2024
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FAQs: Managed Account
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Added a FAQ for robo-advised accounts.
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Jan 2024
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FAQs: Mutual Fund
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Added a FAQ for mutual funds that do not qualify as excepted investment funds. Note: This is a rare case and generally occurs when the filer can exercise some control over the investment selections of the fund.
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Jan 2024
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FAQs: Positions Held Outside of U.S. Government
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Added FAQs for events organized through speakers’ bureaus, donor-advised funds, and professor emeritus status.
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Jan 2024
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FAQs: Sources of Compensation
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Added FAQs for events organized through speakers’ bureaus, book advances, and contingency fees.
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Jan 2024
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FAQs: Stock
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Added a FAQ for preferred securities (i.e., report as stock rather than as a bond).
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Jan 2024
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FAQs: Transactions
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Combined the FAQs for OGE Form 278e and OGE Form 278-T transactions. Added FAQs for stock splits, corporate spin-offs, corporate split-offs, virtual currency transactions, exchange-traded notes, master limited partnerships, real estate investment trusts, non-fungible tokens, fractionalized non-fungible tokens, and exercising options.
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Jan 2024
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FAQs: Trust (irrevocable trust)
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Added a FAQ for intentionally defective grantor trusts.
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Jan 2024
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