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#1394022 - 05/20/10 04:33 PM CTR question - aggregate or not
Data Offline
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Data
Joined: Oct 2002
Posts: 226
Houston
Transactor A comes into the bank with $15,000. $13,000 is deposited to XYZ Corp, $2,000 is deposited to ABC Corp. 2 Section A. Later that same business day Transactor B deposits $1,000 to ABC Corp. Does the $1,000 stand alone or is it aggregated into the CTR?
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#1394148 - 05/20/10 06:04 PM Re: CTR question - aggregate or not Data
Dallas Fan Offline
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In my opinion, if the corporations are under the same ownership I would do the following: Your CTR is for $16,000. You need to fill out two PART 1 Section As with the Corporations' information. Check the multiple persons box and the multiple transactions box. You need to fill out two PART 1 Section Bs because you have two transactors. Lastly, list both account numbers in field #35.

If the corporations are not under the same ownership I would simply file a CTR on XYZ Corp for $13,000 listing the two transactors and check multiple transactions. Lastly, list the account number for XYZ Corp in section #35. There is no need to file one one on ABC if the ownership is different as you only have $3000 being deposited.
Last edited by WyoRockies; 05/20/10 06:20 PM.
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#1394150 - 05/20/10 06:06 PM Re: CTR question - aggregate or not Data
NewTooBSA Offline
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Posts: 568
Texas
Unless XYZ & ABC have the same Tax ID then the $1,000.00 would be aggregated with the previous amount deposited into ABC and that only equals $3,000.00.

So the answer is no. New transactor and amount for ABC does not qualify for CTR reporting.

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#1394182 - 05/20/10 06:35 PM Re: CTR question - aggregate or not Dallas Fan
John Burnett Offline
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John Burnett
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Cape Cod
Originally Posted By: WyoRockies
.

If the corporations are not under the same ownership I would simply file a CTR on XYZ Corp for $13,000 listing the two transactors and check multiple transactions. Lastly, list the account number for XYZ Corp in section #35. There is no need to file one one on ABC if the ownership is different as you only have $3000 being deposited.


The requirement is that you aggregate transactions on behalf of the same party and transactions conducted by the same individual. Since $15,000 was brought in by one conductor, you have to report all of the persons on whose behalf the $15,000 in deposits was made. So you must have TWO Section A entries and, at minimum, one Section B.

The $1,000 cash deposit was made by a second conductor, so it doesn't get aggregated on the basis of a common conductor. If you aggregate the transactions made on behalf of ABC, you get a total of $3,000, so the $1,000 deposit doesn't get reported at all.

Ownership of the two corporations is not relevant unless it's obvious that the only purpose of one of the corporations is to handle funds in ways to avoid CTR filings.
Last edited by John Burnett; 05/20/10 06:36 PM.
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#1394196 - 05/20/10 06:49 PM Re: CTR question - aggregate or not John Burnett
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John has it right. I was over thinking this one and realized it after the post but John beat me to it. Thanks

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