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#540892 - 05/01/06 05:26 PM Same Entity Receiving Benefit???
Bagweaver Offline
Diamond Poster
Joined: Nov 2005
Posts: 2,409
SW GA
We have two accounts that are both dba as the same entity. For example, One Entity dba Your Convenience Store in Trust for Money Orders and Another Entity dba Your Convenience Store in Trust for Lottery Funds. There is one individual that signs on both accounts along with other individuals divided between the two accounts. The deposits to the money order account are a mixture of cash and checks, checks only, and cash only with occasional CTR reporting. The deposits to the lottery account are all cash and have not exceeded $10,000. On occasion combined cash deposits of both entities exceed $10,000.

Should these be considered as the same entity for CTR/SAR purposes?
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#540893 - 05/01/06 05:41 PM Re: Same Entity Receiving Benefit???
blue Offline
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Joined: Jul 2005
Posts: 793
Is the EIN the same on both accounts?

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#540894 - 05/01/06 05:42 PM Re: Same Entity Receiving Benefit???
waldensouth Offline
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waldensouth
Joined: Nov 2001
Posts: 7,974
FINALLY ABOVE the gnat line
The same business owns two DBAs? If yes, then they are one entity. CTRs should be filed on combined cash.
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#540895 - 05/01/06 05:44 PM Re: Same Entity Receiving Benefit???
Bagweaver Offline
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Posts: 2,409
SW GA
Two different EINs.
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#540896 - 05/01/06 05:53 PM Re: Same Entity Receiving Benefit???
blue Offline
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Joined: Jul 2005
Posts: 793
In that case, I believe you would only file a CTR is the same person made deposits to the accounts on the same day and they equalled or exceeded the threshold.
I invite others to correct any errors I made in this assessment. I learn something new every day.

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#540897 - 05/01/06 06:36 PM Re: Same Entity Receiving Benefit???
Bagweaver Offline
Diamond Poster
Joined: Nov 2005
Posts: 2,409
SW GA
No, two entities apparently own one dba.

I'm also not too sure about one of the EINs provided (begins 33-XXXXXXX). Does anyone know if/how an EIN can be verified?

Thanks
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#540898 - 05/01/06 07:33 PM Re: Same Entity Receiving Benefit???
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,659
Galveston, TX
Quote:

No, two entities apparently own one dba.




That, I believe, is impossible.
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#540899 - 05/01/06 07:50 PM Re: Same Entity Receiving Benefit???
Bagweaver Offline
Diamond Poster
Joined: Nov 2005
Posts: 2,409
SW GA
That's what I thought, but according to the account names it is possible.

I'm was reviewing one account for MSB activity and ran across the second account. The more I look at these two accounts, the more interesting things I find. Both of the two entities (money order and lottery) appear to receive funds from the dba.

Possible CTR and SAR filings based on what I've found so far. Have more information I should look at before I do any filings.
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#540900 - 05/01/06 09:16 PM Re: Same Entity Receiving Benefit???
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
I would be very surprised if these 2 entities have different EINs and are truly separate. I would definitly aggregate the deposits and file CTRs.

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#540901 - 05/01/06 09:21 PM Re: Same Entity Receiving Benefit???
Tiger Fan Offline
100 Club
Joined: Jun 2002
Posts: 180
To verify the TIN, go to crimetime.com. It will not tell you who it was issued to, but it will verify whether it is valid or not.

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#540902 - 05/02/06 11:29 AM Re: Same Entity Receiving Benefit???
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:

...according to the account names it is possible




Account names are generally contributed by the customer and, unverified, they offer no proof of existence. In Georgia, you verify the existence of the entity through the Secretary of State's Office and the propriety of the "trade name" through the Clerk of the Superior Court in the county where the business is located.

Your issues cannot be resolved here.
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#540903 - 05/02/06 12:29 PM Re: Same Entity Receiving Benefit???
Bagweaver Offline
Diamond Poster
Joined: Nov 2005
Posts: 2,409
SW GA
Thanks for all the help on this.

Checked with the SOS office and found that one entity was current but the other had been administratively dissolved.
Visited the crimetime.com site but only found a link for verifying SS#s and not TINs.

Guess the next step is to contact the customer(s) and see what happens. Again, thanks to all who responded.
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Semiretired. Working parttime at Historic Westville as a tour guide.

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