We have a local gas station that has 2 separate accounts with 2 different Tax ID numbers. One is for the store, the other is for gas sales. Do I treat this as the same business for CTR reporting or not? For example, if they have a cash deposit in the store account of $3,500.00 and a cash deposit in the gas account for $8,500.00, do I complete a CTR? I think I do, but since there is 2 different Tax ID numbers, I'm second guessing myself.
Thanks!

Review FinCEN's recent opinion on this question: http://www.fincen.gov/statutes_regs/guidance/html/FIN-2012-G001.html

Then based on what you know of the customer, decide whether the two businesses are operated independently of one another. If they are, you don't aggregate. If you believe they are not operating independently (common employees, commingling of funds, transfers of funds between the two, etc.), you should treat them as one "person" on behalf of which the transactions are being made, and combine their activity.

Thank you John! Just what I needed to read. They are definitely not operating independently.

Other clues that two commonly-owned businesses aren't operating independently -- deposits appear to be prepared by the same individual (handwriting, cash bundling style, etc.), both businesses' deposits are in the same night drop bag, or the same individual brings in deposits for both businesses.

We have a customer that is a restaurant that has 3 different restaurant locations in 3 cities, with 3 different tax IDs, but they are owned by the same individual. The 3 restaurants had 3 different individuals make cash deposits that totaled over $10,000 all together. Should we file a CTR since the 3 businesses are owned by the same individual? The funds in the 3 accounts are not comingled but they share a common business mailing address. Thank you.

If the restaurants are owned by entities (LLCs, corporations, for example), and operated independently from one another, you should definitely NOT combine cash transactions based on the common ownership of the entities or their common mailing address.

If, on the other hand, the restaurants are owned by an individual sole proprietor (but for some reason have different EINs), you should be aggregating and reporting under the owner's name (listing the restaurants in the "AKA" field, separated by semicolons if you list more than one), and the owner's SSN, address, DOB, ID info, etc.

See the link in my post above for FinCEN's guidance on common ownership of entities and independent operations.

Start by determining whether the businesses are different entities. (Look at your account opening documentation.) Never make a decision based on how many EINs there are...