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#2286046 - 06/28/23 02:09 PM CTR for an entity with 2 owners
Auditgal Offline
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A husband and wife are both owners of an LLC. The wife deposits $21,000 into the account of the LLC. Should the CTR show 3 Part I's? A 2c for the entity and her husband as "person on whose behalf the transaction was conducted" and a 2a for herself as "person conducting transaction on own behalf"?

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#2286049 - 06/28/23 02:20 PM Re: CTR for an entity with 2 owners Auditgal
rlcarey Offline
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rlcarey
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Galveston, TX
Not sure why the husband would go on the CTR as he was not involved in the transaction. In other words, what would you do in the case that the LLC was owned by a dozen individuals.
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#2286052 - 06/28/23 02:37 PM Re: CTR for an entity with 2 owners Auditgal
John Burnett Offline
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John Burnett
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The ownership of the LLC is irrelevant when filing a CTR. It is a "person" separate from its owners. There is one conductor in your scenario (the wife) and one person on whose behalf the deposit was made (the LLC) . The transaction is not reported as being on behalf of the husband.
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#2286053 - 06/28/23 02:40 PM Re: CTR for an entity with 2 owners Auditgal
Auditgal Offline
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Thank you both!

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#2286055 - 06/28/23 02:51 PM Re: CTR for an entity with 2 owners John Burnett
Auditgal Offline
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If it is a DBA business with a husband and wife as owners and an employee makes the deposit. Is it a Part I for the DBA business as 2c and a Part I for the employee being shown as a 2b? Leave the husband and wife off as in the case of the LLC?
Last edited by Auditgal; 06/28/23 03:07 PM.
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#2286064 - 06/28/23 04:07 PM Re: CTR for an entity with 2 owners Auditgal
John Burnett Offline
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If it is a sole proprietorship with a DBA name you do a part I for the owner with the DBA name added in item 8, and a Part I for the conductor if the conductor is not the owner. If the owner is the conductor, there is only one Part I, with item 2a checked. If the conductor is not the owner, the owner (with the DBA info in item 8) is on a Part I with item 2c checked and the conductor gets a Part I with item 2b checked.

If you're in a state that permits spousal sole proprietorships, the proprietor for CTR purposes is the spouse whose SSN is attached to the account, and you ignore the other spouse's ownership, even if he/she is the joint owner of the account. [Footnote 6 to FIN-2020-R001] Proceed as in the first paragraph. You do not report it as a joint account transaction would otherwise be reported, even if the spouses are joint owners of the account.

For example, Jane and Joseph have a spousal sole proprietorship and both sign on the account as owners, and Joseph makes a reportable cash transaction (deposit or withdrawal) in the account. If Joseph's SSN is on the account, you complete one Part I with Joseph's information in all items. If there is a DBA name, you include it in item 8. Item 2a is checked. Jane does not get a Part I section,

But with the same facts except that Jane's SSN is on the account, you provide a Part I with Joseph's info (he's the conductor) and item 2b checked, and a Part I with Jane's info, item 2c checked, and the DBA name in item 8.
Last edited by John Burnett; 06/28/23 06:01 PM. Reason: error correction and clarity
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#2286070 - 06/28/23 05:42 PM Re: CTR for an entity with 2 owners John Burnett
Auditgal Offline
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Thank you John - one clarification though on the last part of paragraph one: "If the conductor is not the owner, the owner (with the DBA info in item 8) is on a Part I with item 2c checked and the conductor gets a Part I with item 2a checked". Wouldn't the conductor (who is not an owner) get a Part I with 2b checked?

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#2286073 - 06/28/23 06:02 PM Re: CTR for an entity with 2 owners Auditgal
John Burnett Offline
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John Burnett
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I was editing my post when you added yours, Auditgal. I corrected the 2a to make it 2b.
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#2286078 - 06/28/23 06:17 PM Re: CTR for an entity with 2 owners John Burnett
Auditgal Offline
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Ah, great, thank you

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