Illustrative example Not a real client engagement. Every name, EIN, figure, and date below is fabricated to demonstrate the format of Green's §6050I Cash Compliance / Form 8300 deliverable. This describes no actual taxpayer, transaction, or filing.
Working paper · §6050I Cash Compliance / Form 8300

Cash Compliance & Form 8300 Remediation Memo

Remediation — controls build
Client
[Example: Northgate Cultivation LLC]
Engagement
§6050I Cash Compliance / Form 8300 — remediation & controls
Review period
Trailing 12 months + prior open years (illustrative)
Prepared by
Jamie Williams, EA — Enrolled Agent
Date
[Illustrative date]
Status
Threshold review drafted; late filings and controls pending
License posture
Mixed — but §6050I is cash-volume driven, not posture driven
Jurisdiction
California (single location)
Entities in scope
EntityEIN (example)Cash exposurePrimary 8300 trigger
Northgate Cultivation LLC88-0000000High — bulk sales>$10k cash on bulk / wholesale lots
Northgate Retail LLC88-0000001High volume, small ticketsRelated transactions aggregating >$10k

Engagement routing. Tier: Compliance remediation + SOP · Posture: Mixed (§6050I posture-neutral) · Active IRS matter: No · Origin: §280E Risk Review — flagged §6050I exposure (Seq. 3) · Services indicated: none additional — this is the controls build

Prepared for the named operator as a scoped compliance remediation. This example is illustrative and does not constitute tax or legal advice to any reader; no client relationship is created by viewing it, and it describes no real transaction or filing. Cash-reporting compliance is fact-specific; late filings are made with a reasonable-cause statement where the facts support it, and the controls are built to prevent recurrence. Structuring is never advised or facilitated.

02 · Executive Summary

Report every $10,000, on time, and prove it

A cannabis operator handling large volumes of cash must file Form 8300 under §6050I whenever it receives more than $10,000 in cash in one transaction or in related transactions — within 15 days, with an annual written statement to each payer by January 31. Northgate's review found filings that were missing or late and no aggregation process. The engagement remediates the back filings, builds the controls, trains staff, and stands up ongoing monitoring — so the exposure the Risk Review flagged is closed and stays closed.

Key exposure — illustrative

Unfiled or late Form 8300s carry penalties under §6721 / §6722, escalating sharply for intentional disregard, with criminal exposure under §7203 for willful failure and a felony under §6050I(f) for structuring. Exposure is illustrative; the fix is filing correctly and provably, and never structuring to avoid the threshold.

03 · Facts

How cash moves through the business

Facts below are fabricated for illustration; a real review is built from the cash logs, POS records, and prior filings.

Business overview

A cash-intensive California operator — cultivation selling bulk lots and a retail counter taking consumer cash. Federal banking limits keep the business cash-heavy, which is exactly why the §6050I duty is a live, recurring obligation rather than an occasional one.

Cash-handling process

Cash is received at the retail counter and on bulk/wholesale settlements, counted and deposited on a schedule. There is a cash log, but no aggregation tracking across related transactions and no defined point where a threshold transaction is flagged for a Form 8300.

Filing history

Some Form 8300s were filed on paper and late; others that appear to have crossed the threshold were not filed at all; and no January 31 customer statements were furnished. Since 2024, a business filing 10 or more information returns must e-file Form 8300 through the FinCEN BSA E-Filing System — a requirement the current paper process does not meet.

04 · Analysis

The duty, the gaps, and the fix

Threshold transaction review (Form 8300)

§6050I requires a Form 8300 for more than $10,000 in cash received in a trade or business, in a single transaction or in related transactions, filed within 15 days. "Cash" is currency and coin — and also cashier's checks, money orders, bank drafts, and traveler's checks of $10,000 or less received in a designated reporting transaction. Cash from the same payer that aggregates over $10,000 within a rolling 12 months triggers a filing once the threshold is crossed. Each Form 8300 also requires a written customer statement to the payer by January 31 of the following year.

Internal controls

A working control set: a point-of-receipt flag when cash approaches $10,000; an aggregation ledger per payer over the rolling 12 months; a 15-day filing calendar; e-filing via the FinCEN BSA E-Filing System; the January 31 customer-statement run; and a 5-year retention file. Controls are documented as an SOP so the process survives staff turnover.

Missing / late filings

Back filings are remediated: the review identifies each threshold transaction that should have been reported, prepares the late Form 8300s, and files them with a reasonable-cause statement where the facts support one. Voluntary, complete remediation is materially better than waiting for the IRS to find the gap.

Control weaknesses

  • No aggregation tracking — related and same-payer transactions were not summed to the threshold.
  • No structuring red-flag process — no procedure to spot (and refuse to facilitate) a buyer splitting payments to dodge the threshold.
  • No customer statements — the January 31 payee-statement duty was missed.
  • Paper filing — does not meet the post-2024 e-filing requirement.
Cash-intensive-operator emphasis

This is a cash-volume problem, not a §280E problem. §6050I applies to any trade or business; what makes it acute for cannabis is federal banking friction — limited access to banking keeps operators handling large cash, so threshold transactions recur constantly and the filing cadence has to be a standing process.

Transition note: a move to Schedule III and any resulting easing of banking access may reduce cash intensity over time, but it does not change the §6050I duty today. And structuring to avoid the threshold is a felony under §6050I(f) regardless — never a workaround, in any posture.

05 · Issues

Cash-compliance issue register

Each item lists the controlling authority and posture. Conclusions are illustrative and not asserted; a real review turns on the records. Bands are order-of-magnitude illustrations.

IssueControlling authorityIllustrative exposurePosture
Unfiled Form 8300s over the thresholdIRC §6050I; §6721Per-return penalty, escalatingRemediate
Late-filed Form 8300sIRC §6050I (15-day rule); §6721Reduced if reasonable causeFile + explain
Missing January 31 customer statementsIRC §6050I; §6722Separate payee-statement penaltyFurnish
No aggregation of related / same-payer cashIRC §6050I (related transactions)Missed thresholdsBuild control
Intentional-disregard exposureIRC §6721(e); §7203 (willful)Sharp escalation / criminalAvoid
Structuring riskIRC §6050I(f) — felonyCriminal — never facilitateProhibit
Paper filing vs BSA e-file mandatePost-2024 e-file rule; FinCEN BSANon-conforming methodSwitch
06 · Recommendations

Remediation, training & monitoring plan

Owners and targets are placeholders; the remediation is sequenced before the standing controls go live.

StepWhyOwnerTarget
Reconstruct threshold transactions (rolling 12 mo + open years)Find every reportable eventJ. Williams, EA[+21 days]
Prepare + e-file back Form 8300s (reasonable cause)Remediate before the IRS finds the gapJ. Williams, EA[+30 days]
Issue overdue January 31 customer statementsClose the §6722 payee-statement gapEA + client[+30 days]
Stand up the aggregation ledger + 15-day calendarCatch every future threshold on timeClient + EA[+45 days]
Switch to FinCEN BSA e-filingMeet the post-2024 e-file mandateClient[+30 days]
Train counter + bulk staff; set exception trackerSpot thresholds + structuring red flagsEA + client[+45 days]
Standing monitoring
  • Monthly review of the aggregation ledger against POS and deposits.
  • Quarterly staff refresher on thresholds and structuring red flags.
  • Annual January customer-statement run and retention check (5 years).
07 · Exhibits

Supporting shells

Exhibit A — Cash log summary

Illustrative — cash receipts by date, payer, and instrument
DatePayerAmountInstrumentRelated?
[date][Buyer A]$—CurrencyYes — see agg.
[date][Buyer B]$—Cashier's check ≤$10kNo

Exhibit B — Threshold transaction schedule

Illustrative — aggregation to the $10,000 threshold
Payer12-mo aggregate cash8300 required?Filed?
[Buyer A]>$10,000YesNo — remediate
[Buyer C]>$10,000YesLate
[Buyer D]<$10,000Non/a

Exhibit C — Filing checklist

RequirementRuleStatus
File within 15 days of threshold§6050IBuilding
E-file via FinCEN BSAPost-2024 mandateNot yet
Customer statement by Jan 31§6050I / §6722Overdue
Retain copies 5 yearsRecordkeepingIn place

Exhibit D — Staff training log

DateTopicAttendees
[date]Threshold recognition + aggregationCounter + bulk staff
[date]Structuring red flags (§6050I(f))All cash handlers

Exhibit E — Exception tracker

Illustrative — open compliance exceptions by severity
ExceptionSeverityImpactStatus
Unfiled 8300 (Buyer A)HighHighRemediate now
Overdue customer statementsMediumMediumFurnish
Paper filing methodLowMediumSwitch to BSA
08 · Signoff

Findings, actions, and what's open

Key findings
  • Missing and late Form 8300s; no aggregation tracking.
  • January 31 customer statements not furnished (§6722).
  • Paper filing does not meet the post-2024 BSA e-file mandate.
  • No structuring red-flag process — a §6050I(f) felony risk.
Action items
  • Reconstruct thresholds; e-file back 8300s with reasonable cause.
  • Issue overdue customer statements.
  • Stand up the aggregation ledger + 15-day calendar.
  • Train staff; switch to BSA e-filing.
Deadline reminders
  • 15 days from each threshold transaction.
  • January 31 — customer statements.
  • 5-year retention of every filed 8300.
Pending client support
  • Cash logs + POS export for the review period.
  • Copies of any Form 8300s already filed.
  • Buyer/payer records for the aggregation ledger.
Prepared by: Jamie Williams, EA Reviewed: Controls walkthrough — scheduled Next meeting: [Illustrative date]
Cash is fine — unreported cash is the problem

Get your Form 8300 house in order

A licensed Enrolled Agent reviews your cash receipts against the §6050I threshold, e-files the back Form 8300s with reasonable cause, issues the overdue customer statements, and builds the aggregation controls and staff training so it never lapses again. Start with a consult.

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