Part V · Compliance · No. 07

Section 6050I

The statutory hook for Form 8300 reporting. Read together with its Bank Secrecy Act counterpart (31 U.S.C. §5331) and the structuring prohibition (31 U.S.C. §5324), §6050I requires any trade or business that receives more than $10,000 in cash in one transaction or related transactions to report it.

The rule

Under §6050I, any person engaged in a trade or business who, in the course of such trade or business, receives more than $10,000 in cash in one transaction (or two or more related transactions) must file an information return (Form 8300) within 15 days. A parallel Bank Secrecy Act requirement for nonfinancial trades or businesses appears at 31 U.S.C. §5331 and 31 C.F.R. §1010.330; a single Form 8300 satisfies both.

The statutory basis

• 26 U.S.C. §6050I (information return on receipts of $10,000+ in cash).
• 26 U.S.C. §6050I(d) (definition of cash, including certain monetary instruments and, by statute, digital assets).
• 26 U.S.C. §6721, §6722 (information-return penalties).
• 26 U.S.C. §7203, §7206 (criminal exposure).
• 31 U.S.C. §5324 (structuring prohibition).
• 31 U.S.C. §5331 (parallel BSA report for non-financial trades or businesses).
• Treas. Reg. §1.6050I-1, -2.

Scope

"Trade or business" is read broadly. Recurring categories engaged with luxury holdings:

• Art dealers, auction houses, galleries.
• Jewelers and watch dealers.
• Coin and bullion dealers.
• Motor vehicle, boat, and aircraft dealers.
• Real-estate brokerages and title agents.
• Attorneys and other professionals receiving cash fees (there is no general professional exemption).

Rate and computation

Not a tax — an information-reporting obligation. No payment is required; failure to file is a separate civil and criminal violation.

Elections and exceptions

Financial institutions that file currency transaction reports under 31 U.S.C. §5313 are excepted from Form 8300 reporting for those transactions (Treas. Reg. §1.6050I-1(d)). Certain other transactions, such as cash received outside the United States in some circumstances, are also excepted.

The structuring rule

Under 31 U.S.C. §5324 a person may not break a transaction into smaller pieces intended to evade the §6050I reporting obligation. Structuring is a separate offense (§5324(b) for nonfinancial-business reports), punishable as a felony under §5324(d). The structuring offense exists even where no separate tax fraud has occurred.

Interaction with other regimes

• Form 8300 — the operational form. See Form 8300.
• Form 8300 information is shared between IRS and FinCEN; usable for AML, tax, and other federal-criminal investigations.

Common planning approaches

For trades or businesses engaging luxury-asset clients:

• Compliance programs identifying $10,000+ cash receipts and ensuring timely Form 8300 filing.
• Customer identification procedures to obtain required Form 8300 information.
• Training on structuring to ensure neither the business nor the customer engages in structuring conduct.
• Coordination with AML obligations under 31 C.F.R. §1027 for dealers in precious metals and stones.

Recent developments

The Infrastructure Investment and Jobs Act of 2021 (§80603(b)(3)) amended §6050I(d) to treat digital assets as cash, effective for returns required to be filed after 31 December 2023. In Announcement 2024-4 the IRS stated that businesses need not include digital assets in determining whether the $10,000 threshold is met until Treasury and the IRS issue regulations implementing the amendment; as of this review no such regulations have been issued. Separately, Form 8300 must generally be filed electronically from 1 January 2024 by businesses required to e-file other information returns (IR-2023-157). The obligations for traditional cash transactions are unchanged.

Reviewed October 2026