Legal Question in Investment Law in California

how this form would be properly completed on behalf of either of these scenarios below and I believe the key term is "what is REQUIRED":

1st Scenario is on behalf of an IBC/LTD in Anguilla (exchanged at a Dealer in CA that will require use of the Fin104 Form:

Part 1: #14:

Does this section require personal information? i.e. an individual name/ss#?

Section B--Individual(s) Conducting Transaction(s) (if other than above).

If Section B is left blank or incomplete, check the box(es) below to indicate the reason(s):

Note: (None of the Options appear to apply) Please Advise�

Does this section require personal information? i.e. an individual name/ss#? into Section B?

Part II:

Is it required to place the account number here on behalf of the NBA Acct in Anguilla?

Page 2:

Is it required to complete anything else on this page?

-------------------------------------------------

The second scenario is on behalf of a Nevada, LLC (either using the same exchanger or a Wells Fargo/Bank of America branch in California)

Part 1: #14:

Does this section require personal information? i.e. an individual name/ss#?

Section B--Individual(s) Conducting Transaction(s) (if other than above).

If Section B is left blank or incomplete, check the box(es) below to indicate the reason(s):

Note: (None of the Options appear to apply) Please Advise�

Does this section require personal information? i.e. an individual name/ss#? into Section B?

Page 2:

Is it required to complete anything else on this page?


Asked on 3/09/11, 12:32 pm

1 Answer from Attorneys
Bryan Whipple Bryan R. R. Whipple, Attorney at Law

The form you're addressing is, I assume, Internal Revenue Service FINCEN Form 104. It is a four-page form, pages three and four of which are clear and explicit instructions. The instructions for Line 14 say "If an individual conducts the transaction(s) on his/her own behalf, his/her identity must be verified......" etc. You should be able to follow the isntructions if you read them thoughtfully and are not looking for, or hoping for, more privacy than the government is willing to allow. If in doubt, contact the IRS directly. You can also download the form from the IRS website to study it.

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Answered on 3/09/11, 3:51 pm


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