If state law allows spouses to jointly own and operate a sole proprietorship (Oklahoma is an example), they are a sole proprietorship. However, the account is owned by the two individuals, not by the business. Therefore:
1. If Spouse 1 makes a reportable cash deposit to the business account, the CTR is completed as you would for a personal joint account of the spouses, except you include the DBA name (if any) in item 8 of Part I.
2. If a non-owner of the business (let's say it's the owners' daughter) makes a reportable transaction, you would complete a Part I for the daughter as conductor (with item 2b checked), a Part I with 2c checked for Spouse 1 and a Part I with 2c checked for Spouse 2. Include the DBA name in item 8 on the Part I section for each owner.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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