PRP 5380 – IRS Requirement to Report Cash Transactions Over $10,000-IRS Form 8300

Document History

Date Activity Organization
October 17, 2014 Issued as an Interim Policy by VP Loonan. Administration and Finance
October 29, 2014 Reviewed and recommended General Administrative Committee
March 25, 2015 Endorsed University Forum

1. RATIONALE FOR POLICY

The IRS has explicitly declared that state-supported universities are subject to the regulation that cash payments over $10,000 be reported on IRS Form 8300, Report of Cash payments Over $10,000 Received in a Trade or Business. Failure to file a correct IRS Form 8300 by the due date may result in a penalty of $25,000 or more. Criminal penalties and fines up to $500,000 may be assessed for willful violations. To demonstrate compliance with this regulation, PASSHE has directed the state system universities to establish a policy and procedures to ensure that the necessary information is collected and reported.

2. KEYWORDS

Cash transactions, cash payments, IRS.

3. BACKGROUND INFORMATION

Laws passed by Congress require that certain cash transactions be reported to the IRS in an effort to trace money from drug dealers, smugglers, and terrorists, who often use large cash payments to “launder” money from illegal activities, evade taxes, and participate in other criminal activities.

4. POLICY

4.1 Bloomsburg University will file IRS Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, when we receive more than $10,000 of cash in a single transaction or through a series of transactions from the same person within any 12-month period.

  • a. For university transactions, cash is defined as currency and coins of the United States and any other country; it does not include personal checks, cashier’s checks, automated debits or credits, money orders, etc.
  • b. Cash received from tuition, room, board, fees, and other revenue resulting from the normal conduct of university business must be reported.
  • c. Cash receipts of gifts and donations are not required to be reported because the IRS does not consider these transactions as being received in the course of conducting university business.

4.2 All university officers and employees who handle cash transactions and/or are responsible for filing IRS Form 8300 must read and be knowledgeable about:

  • a. IRS Form 8300 and its instructions.
  • b. IRS Publication 1544, Reporting Cash payments of Over $10,000.
  • c. The university established procedures for reporting cash receipts over $10,000.

4.3 The Vice President for Administration and Finance is responsible for:

  • a. Ensuring appropriate procedures are in place to maintain compliance with the requirements of IRS Form 8300.
  • b. Establishing and documenting internal controls to ensure that the procedures are followed.
  • c. Maintaining adequate records.
  • d. Timely and accurately filing IRS Form 8300 when required.
  • e. Providing each person named on IRS Form 8300 with an electronic or written statement indicating the information that was furnished to the IRS in a timely manner.
  • f. Reporting any suspicious transactions, as defined by IRS Form 8300, to the IRS and university legal counsel.
  • g. Ensuring the security of all taxpayer identification numbers collected.

Bloomsburg University’s IRS Form 8300 Reporting Procedures and related documentation