Understanding the Form 8300 e-filing requirements for cash transactions over $10,000

ARTICLE | March 22, 2024

Over the past year, the IRS has taken strides to digitize paper returns and make the filing process more convenient for taxpayers. On March 14th, the IRS unveiled an electronic filing (e-filing) system for Form 8300, Report of Cash Payments Over $10,000. This system is designed to streamline the reporting of cash transactions, reduce costs, and simplify business compliance. 

It’s important to note that the recent introduction of an e-filing system does not change the criteria for who must file Form 8300, but it does mandate electronic filing for certain entities. 

Who must file Form 8300?

Form 8300 must be filed by trades and businesses receiving cash payments over $10,000, whether as a lump sum or in installments that accumulate to over $10,000 within a year, provided the payments are made in the course of their business by the same buyer. The filing requirement is triggered once a business receives payments exceeding the $10,000 threshold rather than by a fixed date. 

Individuals who receive cash payments outside of a business context, like selling personal items, are not required to file Form 8300. 

What are the e-filing requirements?

E-filing Form 8300 is mandatory for businesses filing ten or more information returns. Those filing fewer returns are strongly encouraged to e-file for efficiency and security; however, electronic filing is optional. 

Before e-filing, businesses must register with the Financial Crimes Enforcement Network's (FinCEN) BSA E-Filing System. This system simplifies submission and reduces paperwork.

The e-filing system is free and provides a quicker method to comply with the 15-day reporting deadline following a transaction. Upon submission, businesses will receive a confirmation email from the IRS. The system also allows batching of e-filed reports for businesses required to file numerous forms.

Waivers

Despite the push for electronic filing, the IRS understands that there could be situations where e-filing might pose challenges for certain businesses. These businesses can apply for a waiver using Form 8508, Application for a Waiver from Electronic Filing of Information Returns. Please note that a waiver from electronic filing does not exempt a business from Form 8300 filing requirements; rather, it allows for the submission of Form 8300 in paper format. 

If the IRS approves this waiver, it applies to all Forms 8300 for the remainder of the calendar year. If a waiver is granted, you must clearly mark “waiver” at the top of each paper-filed Form 8300.

In addition to the waivers mentioned above, the IRS respects conflicts arising from religious beliefs. Entities holding such beliefs are automatically exempt from e-filing without the need to file a waiver request. In such cases, the term "religious exemption" must be included at the top of each paper-filed Form 8300.

Resources

Several resources are available for those seeking assistance or further information regarding the BSA E-Filing System. 

The Bank Secrecy Act E-Filing Help Desk can be reached at 866-346-9478 or via email at bsaefilinghelp@fincen.gov. The help desk operates from Monday through Friday, from 8 a.m. to 6 p.m. ET. 

For technical support, you can submit a Self-Service Help Ticket for assistance with e-filing. 

The article is intended to provide a brief overview of the IRS’s new e-filing requirements for Form 8300. If you would like to know whether this filing requirement applies to your business or have any further questions, please contact our office.