Starting January 1, 2024, the Internal Revenue Service (IRS) mandates that businesses electronically file Form 8300, which reports any cash payments over $10,000. This marks a shift from paper-based returns to a more streamlined digital process. The directive follows final regulations issued by the IRS in February, amending the rules for electronic filing of various information returns, including Form 8300.
However, the IRS has made provisions for some exemptions. Businesses that may face difficulties with e-filing can apply for a waiver. Importantly, these forms won't be filed directly with the IRS but through the Financial Crimes Enforcement Network's (FinCEN) BSA E-Filing System. The IRS, FinCEN, and the Treasury Department collectively assess that most businesses that might need a waiver likely wouldn't meet the e-filing threshold requirements in the first place. Even though cash transactions over $10,000 are generally legitimate, the IRS emphasizes that filing Form 8300 is critical in combating tax evasion, drug trafficking revenues, terrorist funding, and other illicit activities. Timely and accurate filing enables governmental tracing of illegal financial activities.
To fulfill this e-filing requirement, businesses must establish an account with FinCEN's BSA E-Filing System. The e-filing mandate also extends to firms obligated to file other kinds of information returns, such as Forms 1099 and W-2. Specifically, if a business must e-file at least ten information returns of any type other than Form 8300 in a given calendar year, then all Form 8300 must also be e-filed. For example, if a business files five W-2 forms and five 1099-INT forms, it must e-file all its information returns, including any Form 8300s. On the other hand, if it files fewer than ten information returns, not counting Form 8300, then e-filing is optional for those particular returns and Form 8300.
A waiver can be requested for businesses struggling with the e-filing transition using Form 8508. If approved, the waiver applies to all Forms 8300 for the remainder of the year. However, it's worth noting that waivers can't be sought solely for Form 8300; they would apply to all information returns. Religious exemptions are also recognized. If e-filing conflicts with a business owner's religious beliefs, they are automatically exempt but must indicate "RELIGIOUS EXEMPTION" at the top center of the paper-filed Form 8300. Lastly, businesses must self-identify if they are filing a late Form 8300. The word "LATE" should be included in the comments section for electronic submissions. For paper returns, "LATE" should be written at the top center of the first page of each Form 8300.
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