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#2269466 - 04/21/22 03:59 PM CTR instruction on DBAs
unknown Offline
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What is the proper way of filing CTRs when you have DBAs?

John Smith dba Computer Shop (using John’s SSN)
John Smith dba Computer Shop (separate EIN)

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#2269469 - 04/21/22 04:15 PM Re: CTR instruction on DBAs unknown
rlcarey Online
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An EIN is issued to John Smith only for tax purposes. It would be used for any sole proprietorship that he operates, whether one or multiple. The number is not even tied to "Computer Shop".
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#2269474 - 04/21/22 05:37 PM Re: CTR instruction on DBAs unknown
unknown Offline
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So, there would only be one Part I?

For ex: John Smith with Computer Shop in the Alternate Name field (regardless of separate EIN)?

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#2269575 - 04/23/22 01:26 PM Re: CTR instruction on DBAs unknown
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#2269790 - 04/28/22 05:52 PM Re: CTR instruction on DBAs unknown
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XYZ, LLC operates with three different DBA names.

XYZ, LLC dba 111 - $5000 cash deposit
XYZ, LLC dba 222 - $5000 cash deposit
XYZ, LLC dba 333 - $5000 cash deposit

Each DBA is located in three separate locations and yet use same EIN for XYZ, LLC.

How many Part I?

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#2269876 - 05/02/22 11:30 AM Re: CTR instruction on DBAs unknown
unknown Offline
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?

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#2269877 - 05/02/22 11:44 AM Re: CTR instruction on DBAs unknown
rlcarey Online
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rlcarey
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Did you not read the FinCEN guidance that I linked above?
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#2269878 - 05/02/22 12:34 PM Re: CTR instruction on DBAs unknown
unknown Offline
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I did read it. However, if there is no “home office”, do we just have Part I for each DBA?

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#2269879 - 05/02/22 12:38 PM Re: CTR instruction on DBAs unknown
rlcarey Online
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Galveston, TX
You stated: Each DBA is located in three separate locations and yet use same EIN for XYZ, LLC.

Guidance states: When multiple entity locations are involved in an aggregated CTR, a separate Part I section should be prepared for each location involved. Each additional Part I section should include the entity’s legal name in Item 4 and alternate name, if any, in Item 8. Each additional Part I section will include the location’s address along with all other location or entity data applicable to that location.
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#2269880 - 05/02/22 12:44 PM Re: CTR instruction on DBAs unknown
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The part that I was scratching my head on was

“The initial part I section on the entity home office/headquarters will show the TOTAL amount and all account numbers involved in Item 21 or 22.”

I wasn’t sure if we needed to do four Part I. And since there is no “home office”, I wasn’t sure if three Part I for DBAs would be good.

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#2269905 - 05/02/22 04:15 PM Re: CTR instruction on DBAs unknown
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If there is no home office, then you report the three locations where the cash came from.
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#2269927 - 05/02/22 06:39 PM Re: CTR instruction on DBAs unknown
John Burnett Offline
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Cape Cod
Are you operating under the February 2020 CTR instructions that were suspended?
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