From: Anne Gross (AGross@nacubo.org)
Date: Fri Aug 02 2002 - 15:20:00 EDT
Brian: I haven't seen other responses to your inquiry, so I'll give you probably more information than you asked for, especially since there is a new requirement for reporting large cash transactions in the USA PATRIOT Act enacted last fall.
First, as to your questions about the requirements for filing IRS Form 8300:
What is considered cash? Generally, just cash. Cashiers checks, bank drafts, or traveler's checks, or money orders count in certain circumstances but for your purposes probably only if (1) their face value is less than $10,000 and (2) you know the payor is trying to avoid having the transaction reported on a Form 8300. Cash does not include a check drawn on an individual's personal account, nor credit card payments.
The rules do require you to look at payments over the course of the year if for a single transaction. I would be inclined to decide that each semester's tuition is its own transaction rather than a single transaction, but since I do not know what usual practice is.
For international students without a TIN, according to the IRS instructions, you do not have to furnish a TIN if the individual does not have US income, file a federal tax return, or a joint return with a spouse who is a US resident or citizen.
Personal checks are not considered cash for anyone.
IRS Publication 1544, Reporting Cash Payments of Over $10,000 is more informative than the instructions to the Form 8300. This 4-page document is available on the IRS web site at http://www.irs.gov/forms_pubs/pubs.html just scroll down the list to 1544.
As to the new requirements, because the Forms 8300 are part of the tax system and subject to certain privacy provisions they are more difficult for law enforcement agencies to access than the "suspicious activity reports" or SARs that banks are required to file with the Treasury Dept's Financial Crimes Enforcement Network. The USA PATRIOT Act requires businesses to begin filing SARs as well as 8300s although my understanding is that they contain the same information. We will be watching for regulations from Treasury about this. Stay tuned. Anne
Anne C. Gross
Assistant Vice President
Business, External Affairs, and Research
NACUBO
202-861-2544 anne.gross@nacubo.org
202-861-2583 (fax)
-----Original Message-----
From: Brian T. Kaspar [mailto:Brian.T.Kaspar@hofstra.edu]
Sent: Monday, July 29, 2002 1:45 PM
To: bursar-l@virginia.edu
Subject: Cash Transactions Greater than $10,000
I am looking to find out how other schools handle cash transactions over
$10,000.00 for a student. IRS Form 8300 is required to be filed for
such transactions.
Do "cash transactions" include personal checks, credit card payments?
Do you handle transactions within a semester as a single transaction or
do you consider each payment a separate transaction?
What about international students who do not have TIN's (Taxpayer ID
number)?
We have heard that personal checks being written by a parent for a
student is considered a cash transaction. Is this true?
Any information would be appreciated.
Thank you.
Brian Kaspar, Hofstra University
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