No, absolutely not. It helps to get away from the idea that you are reporting on who benefits from a transaction (in this case, the corporation's owners benefit only indirectly), and instead understand that you report "on whose behalf" the transaction is completed.
In your scenario, there will be two Part I sections of the report. The first, checking box 2c, is on the corporation. The second, checking box 2b, is for the individual conducting the transaction. There is no person conducting the transaction on his own behalf (2a) entry.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8