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#2033658 - 08/13/15 09:18 PM CTR for single-member LLC
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
I could not find anything recent in the forums for the 'proper' way to handle filing a CTR for a single-member LLC, which uses the individual's SSN, nor did I see anything in the CTR FAQs.

Would it be correct to have two Part Is: the first with the "Person conducting transaction on behalf of another", the individual's name and ssn, AND the second with the "Person benefiting...", the LLC's name and the individual's ssn?

One of them will most likely generate an id mismatch, but I don't know of a better, more accurate way.
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#2033669 - 08/14/15 12:04 PM Re: CTR for single-member LLC Doug Hendrickson
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,544
Cape Cod
I cannot imagine any other way to do it. You are likely to get a mismatch on the LLC portion of the filing, but fortunately it's not (last I knew, anyhow) a fatal error.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2033732 - 08/14/15 04:12 PM Re: CTR for single-member LLC Doug Hendrickson
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Per a senior FinCEN representative, they no longer do name/TIN matches on CTR's & SAR's; no matter what the LLC's name is, you will not get a mismatch by using the sole member's TIN. (Obviously, I can be corrected pretty readily by a filer who's received a mismatch notice in the last couple of years. Please verify it before you say it's so.)

My understanding is that the name/TIN mismatch notice was something the IRS initiated when it was charge of the CTR & SAR data bases just because they thought it was a good idea. FinCEN discontinued it when it assumed control.

In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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