I have a customer that uses the same EIN number for multiple business accounts, the accounts are not set up as DBA's. The account in question is set up as a business account using only the business name and the resolution on file is for Lodge, Association, Organization. I have a returned CTR (others will follow) from the IRS for a mismatch, the name and EIN do not match. I pulled the CIP file and the EIN documentation from the IRS lists one of the business owners and then the name of a different business that is only "seasonal". What would be the correct way to file a CTR in this case????? Thanks for any advice.

I think you may have a problem with the way your accounts are set up. Our system will not allow us to set up multiple accounts using the same TIN/SSN unless we set them up as a DBA. You will continue to have CTRs returned. Also, how can you report to the IRS on these accounts? Your accounts either need to be re-titled as either DBAs or your customer needs to apply for some additional EINs and title the accounts accordingly. At this stage, I dont know how I would fill out a CTR. I would think you have to do so as a DBA. You need to talk to your CSRs about titleing accounts pronto.

Attemptng to get this corrected on account side, CSR is changing accounts to DBAs (example) "Spaghettis Pizza, DBA Spaghettis Pizzaria and Pasta", a total of three accounts set up as "Spaghettis Pizza" with three different DBAs, all using the same EIN. The customer assumed that the three business accounts were set up as sole proprietorships. Also, the IRS told them to use the same EIN for each business. The EIN is assigned only to "Spaghettis Pizza". Is this correct???? This just doesn't seem correct. I am still in the position of filing the CTR's correctly so there are no "mismatches." Thanks for any input.

Attemptng to get this corrected on account side, CSR is changing accounts to DBAs (example) "Spaghettis Pizza, DBA Spaghettis Pizzaria and Pasta", a total of three accounts set up as "Spaghettis Pizza" with three different DBAs, all using the same EIN. The customer assumed that the three business accounts were set up as sole proprietorships. Also, the IRS told them to use the same EIN for each business. The EIN is assigned only to "Spaghettis Pizza".

Have 1 cash deposit for $6,000.00 into Betty Spaghetti's personal account, with a total of 4 joint owners, (all have to be reported). Have another deposit for $9,000.00 for Spaghettis Pizza (sole proprietorship but has not been changed to Spaghettis Pizza DBA Spaghettis Pizzaria and Pasta)using EIN assigned to Spaghettis Pizza. Should I aggregate and report a CTR with all of the multiple benefactors???? Thanks for any input.

You're on the right track. Set up three accounts under SPAGHETTIS PIZZA as primary name and DBA's as the alternate names. All three will have the same EIN. The system should allow this setup. It would be similar to an IOLTA account situation.

For the CTR, I would have both Betty Spaghetti (and the other three owners) plus Spaghetti Pizza as BENEFACTORS and whoever made the deposit as the TRANSACTOR. You will have a total of 5 section A's.

I guess I am really confused.

shenry - you keep saying sole proprietorships. If these are sole propreitorships, they should all be reported under the individual regardless of the fact that the individual DBAs have a separate EIN.

What are the legal status of these entities? Is Spaghettis Pizza a corporation, LLC, etc???

The first thing you have to do is not assume anything about ownership. You have to get documentation that tells you the form of the business organization. If it's an entity, it will be registered as such with the state.

The IRS issued the EIN to either an individual (as sole proprietor) or an entity. Figure out which.

Now you can tell who the owners of your accounts are and you can start determining when and how to complete a CTR for them.

I am also confused. I was told that my state law allows a sole proprietorship to be set up as "Spaghettis Pizza, DBA Spaghettis Pizzaria and Pasta" with a separate EIN than the owner of the account, Betty Spaghetti. ( I understand that a business can be set up and DBA attached, these are usually corporations or LLC's, but sole proprietorship????) I thought that on a sole proprietorship that the owner and the business are recognized as one and the same person, ie: Betty Spaghetti, DBA Spaghettis Pizza, using the owners SS#. BSA officer is taking the customers word that the IRS told customer that they could use the one EIN for all of the DBA businesses as sole proprietorships , I have no documentation other than a copy of the IRS confirmation of the EIN addressed to: Betty Spaghetti, Spaghettis Pizza, does not designate sole proprietorship or DBA. At this point, BSA officer wants to file CTR with the 4 owners of the personal joint account as benefactors and Spaghettis Pizza also as a benefactor, no DBA. The CSR hasn't asked for documentation from customer. Do not want to offend or make customer mad. Thanks your input.

Where is the light at the end of the tunnel????

When things go out of control, sometimes you just have to ask for the customer's cooperation, and asking for documentation concerning how the businesses are registered or owned is not an outlandish or unreasonable request. You MUST determine the true owner of the businesses -- whether they are sole proprietorships, partnerships, LLCs or whatever.

One angle -- It's possible you're dealing with an entity that is doing business under three different assumed names. That's legit. In that case, the entity is the owner.

Now I'm confused too. When you use the term EIN I am assuming (which I should not do) a business as the taxpayer obligor. Follow John's advice above to sort this out.

Yes. EIN assigned to a business. Thanks for everyone's input.