How does Form 8300 cash‑transaction reporting work for precious‑metal dealers and what information is disclosed to the IRS?
Executive summary
Form 8300 is a cash‑transaction reporting rule that obligates precious‑metal dealers to notify the government when they receive more than $10,000 in cash (or related cash instruments) in a single transaction or related transactions, and the form transmits customer and transaction details to IRS/FinCEN for anti‑money‑laundering purposes [1] [2]. It is distinct from capital‑gains or 1099‑B rules: Form 8300 reports the cash received, not the gold itself, while 1099‑B can apply to certain sales reporting requirements for dealers under different thresholds and product lists [3] [4].
1. What triggers a Form 8300 filing for dealers
A dealer must file Form 8300 whenever the business receives more than $10,000 in cash in one transaction or in two or more related transactions—cash meaning U.S. or foreign currency and, in some cases, cash equivalents combined with cash—so that multiple payments within a short window can be aggregated to prevent structuring [1] [5]. Industry guides and dealers consistently echo the $10,000 threshold and the aggregation rule, noting that separate payments intended as one purchase or made within 24 hours are treated as a single reportable event [6] [7].
2. What “cash” counts and what doesn’t
Not all payment methods trigger Form 8300: personal checks, debit/credit card payments, wire transfers and other non‑cash instruments generally are not treated as cash for Form 8300 purposes, whereas physical currency and certain monetary instruments can be [5] [1]. FinCEN/IRS guidance and AML commentary emphasize using the total cash received for the form (Box 29), excluding change returned to the customer, and dealers are instructed to use comments where scenarios are complex [8] [1].
3. Exact information disclosed to the IRS/FinCEN
When filing Form 8300, dealers must provide transaction details and identifying information about the person making the payment—commonly name, address, Social Security number or tax ID, date and amount of cash received, and a description of the transaction—because the form is designed to link large cash movements to identifiable individuals or entities [9] [10]. AML guidance for metals dealers specifically stresses accuracy in reporting the “total cash received” field and including customer identifiers when they are known [8] [9].
4. How this differs from 1099‑B and investor tax obligations
Form 8300 is about cash movement and AML compliance; it does not determine whether a taxpayer owes capital gains taxes—investors remain responsible to report gains even if no Form 8300 or 1099‑B is issued [3] [7]. Separately, dealers may issue Form 1099‑B for certain sales of reportable precious‑metal items under the IRS “reportable items” rules, but 1099‑B covers proceeds reporting, not the receipt of cash [4] [6].
5. Structuring, dealer obligations and enforcement risks
Dealers are explicitly told to watch for structuring—patterns where a buyer splits a payment to avoid the $10,000 threshold—and must aggregate related payments and file if they have reason to believe structuring is occurring; failing to comply can expose dealers (and in certain cases customers) to fines and criminal penalties [4] [6]. Several dealer resources warn that over‑reporting is common but also that under‑reporting carries legal risk, highlighting an industry tension between customer privacy and regulatory compliance [5] [11].
6. Practical limits, disputes and where reporting claims are overstated
Several dealer and market commentaries underline an important nuance: the rule targets cash, not the metal itself, so ordinary purchases paid by non‑cash methods almost never produce Form 8300 filings; some dealers nonetheless disclose more than the law strictly requires, and promotional language can exaggerate how often the government receives precious‑metal purchase data [3] [5]. Public materials also show differing emphases—some stress aggressive enforcement and penalties while others reassure customers most transactions are never reportable—reflecting implicit commercial incentives to both alarm and reassure buyers [6] [11].
7. Reporting mechanics and recordkeeping
Dealers complete Form 8300 (or electronic submission where required) listing the total cash received, customer identifiers, transaction description and any explanatory comments; industry guidance notes Box 29 must reflect total cash and that complex situations should be annotated [8] [1]. The IRS/FinCEN reference and trade‑group guides recommend robust recordkeeping because the filing obligation can hinge on intent, aggregation, and whether identification was obtained at the time of sale [1] [12].