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PROCEDURE & ADMINISTRATION
INDIVIDUALS

A designated reporting transaction $10,000 cash in the transaction. The a sale for federal income tax purpos-
is the retail sale (including through a dealer has no reporting obligation. es) so long as notes or contracts with
broker or intermediary) of a consumer substantially similar terms are used
durable, a collectible, or a travel or Example 6: An individual in the in the ordinary course of the recipi-
entertainment activity.31 A consumer towing industry buys a used tow ent’s trade or business, and the total
durable is an item of tangible personal truck from a dealer for $17,000. The amount of payments that are received
property suitable for personal use that individual pays with $9,500 cash and on or before the 60th day after the
is expected to last for at least one year, a cashier’s check for $7,500. The tow date of sale do not exceed 50% of the
with a sales price greater than $10,000.32 truck is not considered a consumer purchase price;36 or
Standard examples include cars, boats, durable, and thus the cashier’s check 3. They are received in a payment plan
and recreational vehicles. A collectible is not considered cash. The dealer requiring one or more payments and
includes art, rugs, antiques, metals, has not received more than $10,000 the payment of the balance by a date
gems, stamps, coins, alcoholic beverages, cash in the transaction and has no no later than the date of sale, so long
and other tangible personal property reporting obligation. as the recipient uses such payment
specified by the IRS as a collectible.33 plans with substantially similar terms
A travel or entertainment activity is Example 7: A customer leases office in the ordinary course of the recipi-
an item of travel or entertainment space for six months and pays a ent’s trade or business, and such in-
that relates to a single trip or event $1,500 security deposit with a money struments are received more than 60
where the sales price of the item and order at the start of the lease and days prior to the date of the sale.37
all other items pertaining to the same makes six cash payments of $1,500 There is one final development
trip or event that are sold in the same in advance on the first day of each with respect to the definition of cash.
transaction exceeds $10,000.34 month thereafter. This transaction Cryptoassets, or virtual currencies, were
does not involve a consumer durable, not considered coin and currency under
Example 4: An individual purchases and thus the expanded definition the original definition of cash. However,
a large-screen television from a of cash does not apply. The money the Infrastructure Investment and Jobs
consumer electronics dealer for order deposit is not considered cash; Act amended Sec. 6050I to provide that
$11,000 and pays for the item the lessor has not received more than cash now includes any digital asset.38 A
with cash of $5,000 and a cashier’s $10,000 cash and does not have a digital asset is “any digital representation
check for $6,000. The television is reporting obligation. of value which is recorded on a crypto-
a consumer durable, and thus the graphically secured distributed ledger
cashier’s check is considered cash. There are exceptions to the expanded or any similar technology …”39 These
The transaction must be reported by definition of cash that applies in amendments apply to Forms 8300 re-
the dealer. designated reporting transactions, quired to be filed, as well as payee state-
specifically for certain types of loans, ments that must be furnished, after Dec.
Example 5: An individual purchases installment sales, and down payment 31, 2023.40
a Persian rug from a dealer for plans. Cashier’s checks, bank drafts,
$14,000 and pays with cash of traveler’s checks, or money orders are not Reporting under Form 8300
$3,000 and a cashier’s check for considered cash if: Once a person receives more than
$11,000. The Persian rug is a 1. They are proceeds of a loan from a $10,000 cash, reporting on Form 8300
collectible; however, the cashier’s bank;35 is required within 15 days.41 If one
check is not considered cash (it is 2. They are received in payment on a payment is made and requires reporting,
greater than $10,000), and thus the promissory note or installment sales and a customer makes additional
dealer has not received more than contract (including a lease treated as payments within the 15-day period,

31. Regs. Sec. 1.6050I-1(c)(1)(iii). 37. Regs. Sec. 1.6050I-1(c)(1)(vi).
32. Regs. Sec. 1.6050I-1(c)(2). 38. Infrastructure Act, §80603(b)(3), amending Sec. 6050I(d).
33. Regs. Sec. 1.6050I-1(c)(3). 39. Infrastructure Act, §80603(b)(1)(B), amending Sec. 6045(g)(3).
34. Regs. Sec. 1.6050I-1(c)(4). 40. Infrastructure Act, §80603(c).
35. Regs. Sec. 1.6050I-1(c)(1)(iv). 41. Regs. Sec. 1.6050I-1(e)(1).
36. Regs. Sec. 1.6050I-1(c)(1)(v).

36 May 2022 The Tax Adviser