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One Tax ID, Multiple Accounts, and a CTR

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When one tax ID number is used for multiple accounts, each with different DBA names, and the combination of deposits made in one day exceeds the CTR threshhold, are you required to list each DBA as a benefactor?

First, a foundation point: basing filing decisions on common or disparate TINs yields inconsistent results. Instead, focus on who is listed in Section A of the CTR, the "Person on Whose Behalf the Transaction is Conducted." For example, if you have an individual operating several sole proprietorships then her name will be in Section A. If you are aware that aggregated cash deposits to her accounts exceed $10,000 today, you would file a CTR. Whether the businesses have the same or different TINs is irrelevant to the filing decision.

However, your quesiton focuses on how to complete the form, not whether or not to file it. I am not aware of any FinCEN advice on this point, but would encourage you to provide information unique to each sole proprietorship on items 5, 6, and 35. In other words, provide all the information on the DBA names, TINs and account numbers, even though the other information in A, the Person on Whose Behalf the Transaction is Conducted" will not change in any respect. (If the TIN's happen to be the same, I would still provide the unique information in 5 and 35).
It will be necessary to complete the back of the form or attach additional sheets.

First published on 4/01/02

First published on 04/01/2002

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