Form 8300 for Accounting Firms: Cash Over $10,000 Explained

Form 8300 is the form a United States business files with the IRS when it receives more than $10,000 in cash in a single transaction or in related transactions. It is the one part of the US anti-money laundering system that reaches ordinary businesses, not just banks, so it matters to accounting firms that take client payments or advise businesses that handle cash. Our overview of US AML requirements for CPAs covers the wider picture. This guide goes deeper on Form 8300 itself, using the IRS fact sheet on cash reporting and the IRS Bank Secrecy Act page.

Please read "What we could not confirm" at the end. The IRS fact sheet we relied on is dated February 2019 and is marked as an archival document that may not reflect current law, policies or procedures, so every figure here should be checked against current IRS guidance before you act on it.

Who has to file

According to the IRS fact sheet, a "person" who must file includes individuals, companies, corporations, partnerships, associations, trusts and estates. The typical filers it lists are dealers in jewellery, furniture, boats, aircraft or automobiles, pawnbrokers, attorneys, real estate brokers, insurance companies and travel agencies. Tax-exempt organisations are also covered, but not for charitable cash contributions. The list does not name accounting firms, but the obligation is framed around businesses that receive cash, so a firm that did receive more than $10,000 in cash from a client would need to check the current IRS guidance rather than assume it is exempt.

The $10,000 test

The fact sheet says filing is required for cash receipts of more than $10,000 from the same payer or agent. The threshold can be met in three ways: a single lump sum, two or more related payments within 24 hours, or one or more related transactions within 12 months. The word "more" matters, so a payment of exactly $10,000 does not meet the test on its own.

What counts as cash

The IRS describes cash as coins and currency of the United States or any foreign country. A cashier's check, bank draft, traveller's check or money order with a face amount of $10,000 or less also counts when it is received for a designated reporting transaction, or when the recipient knows the payer is trying to avoid a report. A wire transfer is not cash. We did not read the full definition of a designated reporting transaction, so a firm should check it before relying on this summary.

Related transactions

Related transactions are aggregated over a 12-month period. The IRS examples include weekly lease payments and a small purchase that is reportable only if the seller knew, or had reason to know, that the transactions were connected. The practical lesson is that someone in the firm has to be able to see payments from one client together, not payment by payment.

The 15-day deadline

The fact sheet says the form must be filed within 15 days after the business receives the cash. For later payments on a single or related transaction, a new form is filed when the total exceeds $10,000, and again each time payments aggregate above $10,000.

Telling the payer

The business must give the payer a written notice by 31 January of the year after the transaction. The IRS says this must be a single statement aggregating the previous year's transactions, include the filer's name, address and phone number, and state that the payment is being reported to the IRS. For a single transaction, a copy of the invoice or the form may be used if it contains the required information, though the IRS does not recommend sending a copy of the form because it contains sensitive data.

Taxpayer identification numbers

If a customer refuses to provide a taxpayer identification number, the fact sheet says the business should tell the customer the IRS may assess a penalty. If the number cannot be obtained, the business should still file, include a statement explaining the missing number, and keep records of its request.

How to file

Form 8300 can be filed electronically through FinCEN's BSA E-Filing System, which the IRS describes as free, quick and secure, with an electronic acknowledgement for each submission. The IRS Bank Secrecy Act page also says the IRS runs a helpline for general questions about Form 8300 and FBAR filing and provides reference guides for tax professionals who prepare and file these forms for clients.

Form 8300 and suspicious activity

Form 8300 is a threshold report, so it is different from a suspicious activity report. A firm that receives structured cash payments designed to stay below the threshold should understand that the rules look at related payments and at payers who are trying to avoid a report. Our guide to suspicious activity reports and tipping off shows how the UK treats a similar situation.

Our suggestions for an accounting firm

These are our own suggestions, not IRS requirements. Decide as a matter of policy whether the firm accepts cash fees at all, and if it does, record the payer, the amount and the date in one register so related payments can be seen together. Diary the 15-day deadline and the 31 January notice. Train reception and finance staff to recognise a client who splits a payment. For structured study on the wider topic, see our CPD courses.

Frequently asked questions

Is a wire transfer reportable on Form 8300?

According to the IRS fact sheet, a wire transfer is not cash for Form 8300 purposes.

How long do I have to file?

Within 15 days after the cash is received, per the IRS fact sheet.

Do I tell the client?

Yes. A written notice is due by 31 January of the following year.

What we could not confirm

The IRS fact sheet is dated February 2019 and marked archival, so figures and procedures may have changed. It does not state penalty amounts, and we did not read the Treasury regulation that underlies the form, the definition of a designated reporting transaction, or the rules on structuring. We could not confirm whether an accounting firm's professional fees fall within the reporting obligation in particular cases. Always check current IRS and FinCEN guidance. This post is general information, not legal or tax advice.