Answer:
Because the new business is a separate entity, you have to ignore the fact that it shares common ownership with an entity that you already exempt. Put more plainly, you most certainly must wait for 12 months before you can consider exempting the new business.
As long as cash deposits to the exempted business's accounts are in the course of its domestic business transactions, you ignore that part of the cash brought in that goes into the exempt account. Make as if it doesn't happen, then decide whether the rest of the cash on the same business day (deposited to the new business's account and/or other non-exempt accounts), trips the CTR threshold.
You should assure yourselves that your customers are not in any way depositing cash that belongs to the new business into the old business's account and then transferring the funds over (to avoid CTRs for the new business). That would be a form of structuring, as I understand the definition of that term.
First published on BankersOnline.com 07/04/05
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