Truckstop has several operations within it. For example, a store and a restaurant. Different checking accts for these entities but same EIN. For exemption purposes, we did the truckstop business name as there have been enough cash trans. Now, we noticed that some of the restaurant receipts have exceeded $10,000.01 in cash. So, the rest. has the same EIN as the "parent" but different accts with us. Should we file a CTR or does the exemption "umbrella" cover all entities under the same EIN?

Start by verifying that your information on the businesses is correct. Are they, in fact, different businesses operated by the same entity? If so, the entity is your customer, and the entity is what should be exempted.

Make sure that your exemption reflects the true legal name of the entity (not the truck stop's DBA).

If there is one entity that operates both businesses, and if you have filed the exemption designation with the correct name and EIN, the restaurant sits in the shade of the same exemption umbrella.

Its a hugh enterprise. The truckstop is "xyz truck center". Operating within the center is a store, a rest., lodging, etc. The store and resto have a separate name, ie Joe's Resto.Condy's store. Same owner and same EINs throughout. Reading your answer, I'm thinking that the store falls under the "xyz truck center" umbrella, esp. if the EIN is correct. Therefore, as long as the exemtpion was correctly titled "xyz truck center" the transactions for the resto don't have to be reported.....Please let me know if my Friday morning, too much rain clouding my brain reasoning is correct or not. many thanks.

John,

We had the same thing going on with two convience stores with different names but held by another entity. Both of the stores used the same TIN. We contacted FinCEN, and they said to combine the transactions of both to determine if a CTR should be filed.

Trees,

As Andy is fond of saying, "Trust but verify." Make sure you have checked documentation of ownership and that the multiple businesses actually are one entity before pulling them all in under that exemption umbrella.

Bagweaver -- Yes, if owned by the same entity, combine for either CTR reporting purposes or for CTR exemptions.