Administrative Procedure 8.760 Administrative Procedure 8.760


IRS Compliance for Reporting Cash Payments Over $10,000


Administrative Procedure Chapter 8, Business and Finance
Administrative Procedure AP 8.760, IRS Compliance for Reporting Cash Payments Over $10,000
Effective Date:  March 2015
Prior Dates Amended:  September 2009, August 2010    
Responsible Office: Office of the Vice President for Budget and Finance/Chief Financial Officer
Governing Board and/or Executive Policy: EP 1.102, Authority to Manage and Control the Operations of the Campus
Review Date:  August 2018

I. Purpose

To establish guidelines and responsibilities for the proper recording, tracking, and reporting of more than $10,000 in cash, in any 12-month period, in a single transaction or in two or more related transactions in accordance with Internal Revenue Code (IRC) §6050I.

II. Definitions

A.  Cash - Coins and currency of the United States.  Cash includes currency equivalents such as cashier’s checks, money orders, bank drafts, or traveler’s checks with a face value of $10,000 or less.  For the purposes of this procedure, the following additional guidelines apply:

    - Cash does not include cashier’s checks, money orders, bank drafts or traveler’s checks with a face value of more than $10,000.  These items are not defined as cash and do not need to be filed on Form 8300 when received because if they were originally bought with currency, the bank or other financial institution that issued the item(s) would have previously filed a report to account for the transaction.

    - Cash does not include a cashier's check if it constitutes the proceeds of a bank loan.

    - A personal check is not considered cash regardless of the amount.

    - The filing of Form 8300 does not apply to wire transfers.

B.  Related Transaction - Any transactions between a buyer and a seller that occurs within a 24-hour period are related transactions.  Transactions can also be related even if they are more than 24 hours apart if you know, or have reason to know, that each transaction is one of a series of connected transactions.  An example of related transactions is tuition payments for the same term paid in cash within a twelve-month period totaling $10,000 or more.

III. Administrative Procedure

A.  General

    1.  In accordance with IRC §6050I, each person/business engaged in a trade or business who receives more than $10,000 in cash, in any 12-month period, in a single transaction or in two or more related transactions, must file Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, with the Internal Revenue Service (IRS) within 15 days of the transaction(s).  The IRS reports this information to the Financial Crimes Enforcement Network (FinCEN).  A transaction may not be divided into multiple transactions in order to avoid the filing of IRS Form 8300. For University purposes, transactions include, but are not limited to, payments for tuition, fees, room, and board, consumer durables (for example a personal computer) and athletic tickets.

    2.  Additional information is available in IRS Publication 1544, Reporting of Cash Payments Over $10,000.

B.  Applicability

    1.  University employees who accept payments are required to track cash payments greater than $10,000 by completing the Form 8300 Tracking Spreadsheet (Attachment 1) and a Form 8300 for applicable transactions.

    2.  A Form 8300 must be prepared as soon as the occurrence of a single transaction or two or more related transactions with a cumulative amount of greater than $10,000 is received from one individual within any 12-month period.

C.  Responsibilities

    1.  Departments

        a.  Prepare and submit a Form 8300 Tracking Spreadsheet and Form 8300 for any cash payments over $10,000 to the Treasury Office no later than 5 days after receipt.  The Form 8300 must be completed at the time the cash is accepted because University employees are required to enter and/or verify information on the Form 8300 such as:

            (1)  Taxpayer Identification Number (TIN) of the individual

            (2)  Name and address of the individual

            (3)  Identifying document number

            (4)  Date cash received

            (5)  Total cash received

            (6)  Dollar amounts of each form of cash received

            (7)  Serial numbers of monetary instruments

        b.  After an initial Form 8300 has been filed on an individual, a new count of cash payments received from that individual must be tracked. If more than $10,000 in additional cash payments is received from that individual within a 12-month period, another Form 8300 must filed within 15 days of the payment that causes the additional payments to total more than $10,000.

        c.  If cash in the amount of $10,000 or less is received, Form 8300 may be voluntarily filed if the transaction appears to be suspicious.  Generally, a transaction is suspicious if it appears that a person is trying to cause Form 8300 not to be filed, is trying to cause a false Form 8300 to be filed, or if there is a sign of possible illegal activity.

    2.  Treasury Office

        a.  Review all Form 8300 Tracking Spreadsheets and Form 8300 submitted by departments.

        b.  Sign, date, and submit Form 8300 within 15 days of the transaction(s) to:

            Internal Revenue Service
            Detroit Computing Center
            P.O. Box 32621
            Detroit, MI  48232
        c.  Prepare annual statements to individuals for whom a Form 8300 was submitted by the University no later than January 31 of the year following the calendar year that Form 8300 was filed.  This statement must contain (1) the University' s name, address, and phone number of a contact person and (2) the aggregate amount of cash received by the University (see Attachment 2).
        d.  Retain copies of all Forms 8300 and annual statements to individuals for a minimum of five (5) years.

IV. Delegation of Authority

There is no administrative specific delegation of authority.

V. Contact Information

VI. References

    A. Link to superseded Executive Policies in old format
    B. Link to Administrative Procedures in old format

VII. Exhibits and Appendices

Attachment 1:  Form 8300 Tracking Spreadsheet
Attachment 2:  Sample Annual Statement Letter to Individuals


    Kalbert Young    
    March 12, 2015    
    Vice President for Budget and Finance/Chief Financial Officer


IRC Section 6050I; $10,000 cash; Form 8300