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The IRS doesn't seem to make a distinction, calling out bank transfers by bank customers explicitly in it's structuring regulations: https://www.irs.gov/irm/pa
by monocasa 4y ago
The IRS doesn't seem to make a distinction, calling out bank transfers by bank customers explicitly in it's structuring regulations:
https://www.irs.gov/irm/part4/irm_04-026-013 https://www.irs.gov/irm/part4/irm_04-026-013
- nulbyte 4y agoCheck the definition at 4.26.13.3.1. The third element of structuring is conducting a transaction in currency, and the last element is for the purpose of evading specific reporting requirements, where each of those reporting requirements involve transactions in currency. This is from the Bank Secrecy Act. The other type of transaction they mention in 4.16.13.4 also involves cash payments in the course of a trade or business. Everything else is what someone might do to try to conceal structuring, but if cash isn't involved, it's not structuring, because there's no covered reporting requirement.
- monocasa 4y agoThe defintion in 4.26.13.3(1)(f) makes it clear that it covers the evading the "Recordkeeping requirements for transmittal of funds at $3,000 and above, additional records to be made by a dealer in foreign exchange at $1,000 and above, and records to be made by casinos and card clubs" as well.