To clarify, john does owns 2 businesses. one has two accts. Each have their own EIN, and both are LTDs. He made the deposit to each in person. So, please advise how the CTR should be completed. Multiple trans. multiple persons at the top. I am thinking his personal info in part 1A. Check conducted on own behalf in B. Then, on separate pages, part 1 Sec. A for one company and another part 1 section a for the other....right???

Companies in Section As

Person in Section B.

No to Trees.

Let's assume that there is a cash deposit of $6,000 to Business A and a cash deposit of $6,000 to Business B. Both businesses are owned by John. If the businesses are both legal entities (you said "LTD" which means nothing to me in Massachusetts, but I'm going to assume they are either LLCs or corporations), you won't aggregate the transactions based on the companies, or on John's ownership of them (entities stand on their own), but you will aggregate based on the fact that the same individual (John) conducted both transactions.

John is not listed in a Part A entry because he is not a person benefiting from the transaction (in spite of his ownership of the two entities). Business A is listed in one Section entry and Business B is listed in a second Section A entry. Multiple transactions and multiple persons are checked in item 1.

John's information is recorded in Section B because he's the conductor of the transactions. You only list him once, on the front.

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Now, change things a bit, and make Business A and Business B John's sole proprietorships. In this case, John and the businesses are one legal person -- John. So John is listed as benefiting from the transactions. He doesn't own the businesses as entities, he IS the businesses. Because of the flexibility found in FinCEN 2008-R001 (FinCEN's ruling on CTRs for DBA-type businesses), you can create one Section A entry for John, with Business A and Business B listed in item 5; you can create one Section A entry for John with Business A in item 5 and a second Section A entry for John, with Business B in item 5; or a three-Section-A CTR with entries for John, Business A and Business B. In this case, because John is listed in Section A, you can complete Section B by checking item B(e) - Conducted on own behalf.

Doe has a joint with the Deer. He also has an DBA. Same TIN?EIN. Doe comes in and deposits $ to his business as well as his joint account with the Deer. We were going to put the business info part 1A,Doe's info on Sec. B and then the Deer's info on part 1A multi person's page. We checked multi trans/multi person at the top of the CTR. Right???

And where did Doe and the Deer get this joint? LOL

We'll start by assuming that "He also has an DBA" means he operates a sole proprietorship (SP). The TIN/EIN is only a hint. It doesn't decide who gets combined with what.

Doe benefits from any deposit to the joint account with Deer. He also benefits from any deposit to his SP account.

Once again, Doe and the SP are one and the same person. Whom do you put in Section A entries? Doe and Deer. Under the DBA ruling I reference above, you can list the DBA name of the business in item 5 of Doe's Section A entry, or you can create a separate Section A entry for the business. It matters not, but if you create the separate business Section A, put business information there (address, type of business). Of course, since it's an SP, you'll list Doe in items 2 - 4.

If you have Doe listed on the front in Section A, you complete Section B with a check mark in item B(e) - Conducted on own behalf, because Doe conducted the transactions. You have completed item 1 correctly.

Since part of the deposit was for Doe's benefit I would list him in first Section A- check conducted on own behalf in section B. If the business is a sole proprietorship I would show the name of his business on line 5 of the first Section A- if not, show the business on a separate Section A, and list Deer on a separate Section A. Yes on multiple transaction, persons. Hope I didn't confuse things.