We have an NRA with no TIN and has a DBA with an EIN that conducted a transaction needing a CTR. Would you file one Part 1 for the NRA with the DBA information and have the EIN number in the tax ID field? Or would there be two separate Part I's, one for the NRA customer and one for the DBA? Would the same be said for someone with a SSN and the DBA has it's own EIN? Will this change with the new FinCEN ruling?

Thank you!

You have described a situation that is just not possible. A NRA without a taxpayer ID cannot do business in the United States - EIN or not.

I would contact FinCEN and have them tell you what to do