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One of our customers is a single-member LLC with no employees. It is fully owned by another LLC. The IRS told us that the two LLCs do not need separate taxpayer identification numbers (TINs). How should we title the accounts for each LLC to avoid TIN reporting errors? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

One of our customers is a single-member LLC with no employees. It is fully owned by another LLC. The IRS told us that the two LLCs do not need separate taxpayer identification numbers (TINs). How should we title the accounts for each LLC to avoid TIN reporting errors?

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The bank either should develop a way to “flag” the account in its system to indicate that no TIN is needed, or it should develop a policy and practice whereby the bank assigns a type of title to the account that lets it know that no TIN is needed (for example, “LLC 1, a subsidiary of LLC 2”).