How does Form 8300 aggregation work in practice for multiple precious‑metal sales over several days?
Executive summary
Form 8300 requires businesses to report receipt of more than $10,000 in cash in one transaction or in two or more related transactions, and dealers in precious metals must aggregate multiple payments that are part of a single purchase or a series of connected purchases even when those payments occur over days, not just within 24 hours, if the dealer knows or has reason to know they are related [1] [2] [3]. In practice this means precious‑metal dealers must watch for repeated cash or cash‑equivalent payments from the same customer and file within strict deadlines once aggregated receipts cross the $10,000 threshold [4] [5].
1. How "aggregation" is defined and applied in real transactions
The IRS and industry guides treat aggregation as a facts‑and‑circumstances test: payments made toward a single purchase or “two or more related transactions” must be combined to determine whether the $10,000 cash threshold is met, and “related” can reach beyond a 24‑hour window when the recipient knows or has reason to know the transactions are connected [3] [2] [6]. Multiple reputable dealer and IRS sources emphasize that the rule is aimed at preventing structuring—breaking a large cash purchase into smaller payments to avoid reporting—so dealers are expected to aggregate payments across days when the pattern or common motive is apparent [7] [5].
2. What counts as "cash" and which tenders trigger aggregation
Aggregation is not limited to paper currency: the IRS defines cash broadly for Form 8300 purposes to include cashier’s checks, bank drafts, traveler’s checks, and money orders with face amounts under $10,000, and those instruments are treated as cash in aggregation analyses [8] [4]. Conversely, ordinary checks and electronic transfers generally are not “cash” for Form 8300, meaning aggregation obligations focus on the tender type as much as the timing [8] [1].
3. Dealer duties: identification, timing, and notification
When aggregated cash receipts exceed $10,000, the dealer must file Form 8300 within 15 days of the receipt that brings the aggregate over the threshold and must provide a written statement to each person named on the form by January 31 of the following year, including business contact details and the aggregated amount [4] [1]. Dealers are also expected to collect identifying information (name, address, TIN) and to verify identity when filing becomes required, because the form feeds law‑enforcement and FinCEN databases used to combat money‑laundering [5] [4].
4. Practical examples, gray areas, and dealer judgment calls
Industry write‑ups and IRS guidance offer common hypotheticals: two $6,000 cash payments on consecutive days must be aggregated and reported because together they exceed $10,000; similarly, $7,500 now and $7,500 later for the same agreed sale will trigger an 8300 once aggregate cash received crosses $10,000—even if payments fall on different days—putting a premium on documenting whether payments are part of one sale or separate transactions [5] [9] [10]. That factual determination—was there a single agreement, a common motive, or evidence of structuring—is where dealers often face uncertainty and where IRS examinations focus money-laundering-rules/" target="blank" rel="noopener noreferrer">[11].
**5. Penalties, enforcement priorities, and motives behind the rule**
Penalties for failure to file or for intentional disregard can be severe, running from monetary fines to criminal sanctions; the policy rationale is explicit: Form 8300 creates an audit trail to deter money laundering, tax evasion and related crimes, and IRS examiners have been targeting jewelry and precious‑metal dealers for compliance reviews [3] [11] [6]. Industry sources caution that a filed 8300 is not an accusation of wrongdoing but a statutory reporting duty; critics and some dealers push back, arguing the measure sometimes sweeps up ordinary customers and raises privacy concerns [10] [8].
6. Bottom line and limits of this reporting on investor taxes
Aggregation for Form 8300 is a transaction‑level compliance rule focused on the nature and pattern of cash receipts; it does not itself determine capital‑gains tax liability for the seller (profits must be reported separately), and several trade guides urge consultation with tax counsel because real‑world sales can hinge on nuances—what constitutes a related transaction, how cash equivalents are treated, and how to document intent and identity when multiple payments span days [7] [8] [9]. The sources reviewed set clear expectations for dealers to aggregate and report when facts indicate connected cash payments, but gray areas remain and professional advice is commonly recommended [1] [11].