Can a partnership report under one of the partner’s social security number, rather than filing for a EIN?
We have to file a CTR for a cash deposit to an account of a single member LLC that uses its member's Social Security number instead of an EIN. Should we use the 2008 DBA ruling from FinCEN as a "go by" to complete the CTR?
We have an attorney who wants to open an escrow account; however, the funds are from an estate that is being contested. He wants to open the account with the deceased's SSN. Should he not have to get a tax ID number?
It’s my understanding that for CIP of a US citizen a driver’s license number is not a valid ID number, but a that a TIN is required as an ID number, correct? If so, where can I find the citation/rule?
Our credit union has always opened trust accounts and allowed the trust to be listed with the trustee's social security number if a TIN was not assigned. Someone now told us we should let the ownership only reflect the trustee's with their respective SSNs if we have no tax ID number. Is this true?
If an irrevocable trust is set up whom do we CIP, the trustees, the beneficiaries?
An individual purchases a bank check with cash for $4,000. This person is a signer on a commercial checking and has a commercial loan with us, but does not have a deposit account relationship in his name. Should we gather additional information for the non-deposit instrument log (address, TIN, birth date)?
We have several attorneys who maintain IOLTA accounts with our bank. They all use the same tax ID and their transactions aggregate on the large cash transaction report. If they are acting independently, would we still need to aggregate the transactions for CTR reporting?
Who is the beneficiary when a large cash deposit is made into an attorney's state bar client trust account and a CTR is required to be filed? The account uses the state bar TIN and the attorney refuses to divulge his client's information.
Can a bank require a non-resident alien to have a Federal Taxpayer Identification number to cash one of our client's checks for over $10,000? If we do not require this information how do we complete the CTR?