Archive for the ‘Gambling’ Category

Online Gambling and Cryptocurrency Addresses for 2024

Thursday, February 8th, 2024

If you have one or more foreign financial accounts and you have $10,000 aggregate in those account(s) at any time during 2023, you must file the Report of Foreign Bank and Financial Accounts (the “FBAR”). This is Form 114 from FINCEN. (The IRS and FINCEN now allege that foreign online poker accounts are “casino” accounts that must be reported as foreign financial accounts. The rule of thumb, when in doubt report, applies—especially given the extreme penalties.) You also should consider filing an FBAR if you have $10,000 or more in a non-US Cryptocurrency Exchange.

There’s a problem, though. Most of these entities don’t broadcast their addresses. Some individuals sent email inquiries to one of these gambling sites and received politely worded responses (or not so politely worded) that said that it’s none of your business.

Well, not fully completing the Form 114 can subject you to a substantial penalty. I’ve been compiling a list of the addresses of the online gambling sites. It’s presented below.

FINCEN does not want dba’s; however, they’re required for Form 8938. One would think that two different agencies of the Department of the Treasury would speak the same language…but one would be wrong.

You will see the entries do include the dba’s. Let’s say you’re reporting an account on PokerStars. On the FBAR, you would enter the address as follows:

Rational Intellectual Properties Limited
Douglas Bay Complex, King Edward Rd
Onchan, IM31DZ Isle of Man

Here’s how you would enter it for Form 8938:

Rational Intellectual Properties Limited dba PokerStars
Douglas Bay Complex, King Edward Rd
Onchan, IM3 1DZ Isle of Man

You will also see that on the FBAR spaces in a postal code are removed; they’re entered on Form 8938. You can’t make this stuff up….

Foreign cryptocurrency exchanges with just cryptocurrency do not have to be reported on the FBAR. However, if the account holds anything else (such as ‘fiat’ currency like US dollars, Euros, etc.) the account is reportable.

There is no dispute, though, about reporting foreign cryptocurrency exchanges on Form 8938: They must be reported on Form 8938 (if you have a Form 8938 filing requirement).

Note: This list is presented for informational purposes only. It is believed accurate as of February 8, 2024. However, I do not take responsibility for your use of this list or for the accuracy of any of the addresses presented on the list.

The list is in the cut text below.

The list is in alphabetical order by the common name (not the legal name) of the gambling site. An entry is:

Common Name
Legal Name
Address
City, State/Territory, Postal Code, Country

Note that not all entities have states/territories or postal codes.

IMPORTANT: When reporting on Form 114, the dba’s are not included. When reporting on Form 8938, the dba’s are included.

10Bet
Ocean Star Limited dba 10bet.com
Dragonara Business Center, 5th Flr, Dragonara Rd
St. Julians, STJ3141, Malta

12Bet (except U.K.)
Pacific Sea Marketing International Ltd. dba 12bet.com
MillMall, Ste 6, Wickhams Cay 1, PO Box 3085
Road Town, Tortola, British Virgin Islands

12Bet (U.K.)
TGP Europe Limited dba 12bet.uk
22A Castle St
Douglas, IM1 2EZ, Isle of Man

188Bet
Cube Limited dba 188bet
Ground Floor, St. George’s Court, Upper Church St
Douglas, IM1 1EE, Isle of Man

5dimes
5Dimes Casino and Sportsbook
Edificio Equus
San Jose, Costa Rica

888poker (except U.K.)
Virtual Digital Services Limited dba 888 Poker
Level G, Quantum House; 75, Abate Rigord St
Ta’Xbiex, XBX1120, Malta

888poker (U.K.)
888 UK Limited dba 888 Poker
Ste 601-701, Europort
Gibraltar, Gibraltar

AA Poker
Memoriki Limited dba AA Poker
18/F, Star Centre, 35 Hung To Rd, Kwun Tong, Kowloon
Hong Kong, Hong Kong

America’s Cardroom
BMX Entertainment S.A. dba America’s Cardroom
Sabana Sur, Edificio La Colmena Contigo a Grupo Sama
San Jose, Costa Rica

Asianconnect88
Asianconnect N.V. dba Asianconnect88
E-Zone Beheer van Engelen N.V., Van Engelenweg 21A
Willemstad, Curacao (Netherlands Antilles)

BestPoker
Best Global N.V. dba Best Poker
BS Building, Level 1, Triq Il-Mosta,
Lija, LJA 9012, Malta

Bet365
Bet365
Hillside, Festival Way, Stoke-on-Trent
Staffordshire, ST1 5SH, United Kingdom

Betanysports Casino and Sportsbook
Betanysports Casino and Sportsbook
Edificio Equus
San Jose, Costa Rica

BetCaliente
Tecnologia en Entretenmiente Caliplay S.A.P.I. DE RL DE CV dba BetCaliente
Avenida Cententario Modulo 4 Parte
Tijuana, BCN 22010 Mexico

Betclic
Managas Gaming Malta Limited dba Betclic
Level 3, Tagliaferro Business Center; High St c/w Gaiety Ln
Sliema, SLM1551, Malta

Betcoin.ag
Global Limiting Holding EOOD dbaBetcoin.ag
Nikola Vaptsarov Blvd
Sofia, Bulgaria

BetCris
TV Global Enterprises Ltd dba BetCris
Villa Seminia, 8 Sir Temi Zammit Ave
Ta’Xbiex, XBX1011 Malta

BETDAQ
LC International Limited dba BETDAQ
Ste 6, Atlantic Suites
Gibraltar, Gibraltar

BETDSI
Diamond Sportsbook International dba BETDSI
Santa Ana
San Jose, Costa Rica

Betfair
PBB Counterparty Services Limited dba Betfair
Triq il-Kappillan Mifsud
St. Venera, SVR1851, Malta

Betfred
Petfre (Gibraltar) Limited
5/2 Waterfront Place
Gibraltar, Gibraltar

Betmost Poker
WHG (International) Limited dba Betmost Poker
6/1 Waterfront Place
Gibraltar, Gibraltar

Betnow.eu
Betnow.eu
14 Garrick St
London, WC2E 9SB, United Kingdom

Betonline
BLS International dba Betonline.ag
cs@betonline.ag
Panama City, Panama

BetPhoenix
International Radical Investment S.A. dba BetPhoenix
San Jose Paseo Colon, Condomino 6-30, Torre A, Apartamento 1201
San Jose, Costa Rica

Betsafe
BML Group Ltd Limited dba Betsafe Poker
Betsson Experience Center, Ta’Xbiex Seafront
Ta’Xbiex, XBX1027, Malta

Bettson
BML Group Ltd dba Bettson
Betsson Experience Center, Ta’Xbiex Seafront
Ta’Xbiex, XBX1027, Malta

BetUS
Firepower Trading Ltd dba BetUS
Anthinodorou, 3 Dasoupoll, Strovolos
Nicosia, 2025, Cyprus

betusa.ag
Online Management Services dba betusa.ag
Jasmine Ct, Ste 17, Friar’s Hill Rd
St. Johns, Antigua

BetVictor
Victor Chandler International Ltd dba BetVictor
Ste 23, Portland House, Glacis Rd
Gibraltar, Gibraltar

Binance
Binance Marketing Services Limited
C85602 Melita Ct, Level 3, Triq Giusseppe Cali
Ta’Xbiex, XBX1420, Malta

Bitfinex (non-US users)
BFXNA Inc dba Bitfinex
Ste 13/F, 1308 Bank of America Tower, 12 Harcourt Rd, Central
Hong Kong, Hong Kong

Bitfinex (US users)
Finex Inc. dba Bitfinex
Chaucer Group Limited, 10 Lower Thames
London, E3R 6E14, United Kingdom

BitMax.io
BitMax.io
114 Lavender St, #09-88, Ct Hub 2
Singapore, 338729, Singapore

BitMex
100x Grouop dba BitMex
Second Flr, Capital City, Independence Ave, PO Box 1008
Victoria, Mahe, Seychelles

Bitrue
Bitrue Singapore Pte. Ltd.
73 Upper Paya Lebar Rd, #06-01C, Centro Bianco
Singapore, 534818, Singapore

Bitstamp
Bitstamp Ltd.
5 New Street Square
London, EC4A 3TW, United Kingdom

Black Chip Poker
BMX Entertianment S.A.
Sabana Sur, Edificio La Colmena Contigo a Grupo Sama
San Jose, Costa Rica

Blockchain
Blockchain.info
Rue de Merl, 741, Rue Phillipell
Luxembourg, 2340, Luxembourg

Bluetrade.com
Bleu Digital Enterprises Ltd
527, St. Paul’s St
St. Paul’s Bay, Malta

Bodog
Connaught Media BV dba Bodog
Kaya Richard J Beaujon Z/N, PO Box 6248
Willemstad, Curacao (Netherlands Antilles)

Bookmaker.eu
Costa Rica International Sports dba Bookmaker.eu
Edificio La Colmena; 75m W Contraloria de la Sabana Sur
San Jose, Costa Rica

Bovada
Lynton Limited Ltd dba Bovada
Craig Plaza, 51-55, Fountain St
Belfast, BT1 5EB, United Kingdom

Boylesports
Boylesports Ltd
Finnabair Industrial Estate, Dundalk
County Louth, Ireland

Bwin
ElectraWorks Limited dba BWIN
Ste 6, Atlantic Suites, Europort Ave
Gibraltar, Gibraltar

Cafe Casino
Lynton Limited dba Cafe Casino
Craig Plaza, 51-55 Fountain St
Belfast, BT1 5EB United Kingdom

Carbon Poker
PDC Global Collections Ltd dba Carbon Poker
19/21 Circular Rd
Douglas, Isle of Man

CaribSports
Carib International Entertainment Ltd dba CaribSports
35 New Rd
Belize City, Belize

Cashpoint
Cashpoint (Malta) Ltd.
Level 1, Salvu Psaila St
Birkirkara, BKR9077, Malta

Casino77
Mandarin Gaming NV dba Casino 77
Soho Office 3A, Edge Water Complex, Elia Zammit St
St. Julians, Malta

Celeb Poker
Wizplay OS (Cyprus) Limited dba Celeb Poker
Flat 22, 6 Tassou Papadopolou St
Agios Dometios, Nicosia, 2372, Cyprus

Celsius Network Limited
Celsius Network Limited
The Harley Bldg, 77-79 New Cavendish St
London, W1W 6XB, United Kingdom

CEX
CEX.io Ltd
24th Flr, One Canada Square, Canary Wharf
London, E14 5AB, United Kingdom

Click and Buy
Click and Buy International Ltd
6-9 Cynthia St
London, N1 9JF United Kingdom

Cloudbet
Halcyon Super Holdings BV dba Cloudbet
Pareraweg 45
Willemstad, Curacao

CoinEgg Ltd
CoinEgg Ltd
38 Hunstanton Ave
Birmingham, B17 8TA, United Kingdom

CoinLoan
CoinLoan
Lastekodu 25-38
Tallinn, Estonia

Coinmate
Confirmo Ltd. dba Coinmate
The Shard Floor 24/25, 26 London Bridge St
London, SE1 95G, United Kingdom

ComeOn! Poker
Co-Gaming Limited dba ComeOn! Poker
3rd Flr, Spinola Park, Tirq Mikiel Ang Borg
St. Julians, SPK1000, Malta

Coral Poker
Gala Interactive (Gibraltar) Ltd dba Coral Poker
Ste 6, Atlantic Suites
Gibraltar, Gibraltar

Crypto.com
Foris DAX Asia Pte. Ltd. dba crypto.com
#25-01, 1 Raffles Quay, North Tower
Singapore, 048583, Singapore

Crypto.games
MuchGaming B.V. dba crypto.games
Fransche Bloemweg 4
Willemstad, Curacao

CryptoPay
CryptoPay
WeWork Bldg, 12 Hammersmith Grove
London, W6 7AP, United Kingdom

CurrencyFair
CurrencyFair Ltd
Colm House, 91 Pembroke Rd
Ballsbridge, Dublin, Ireland

Dafabet
Bayvieew Technologies Ltd dba Dafabet
RCBC Plaza, Makati
Cagayan Valley, Philippines

Diamond Sportsbook
Diamond Sportsbook International dba BETDSI
Santa Ana
San Jose, Costa Rica

DuckDice.io
Sabant B.V dba DuckDice
Heelsumstraat 51, E-Commercepark Unit 102
Willemstad, Curacao

ecoPayz
PSI-Pay Ltd dba ecoPayz
Afon House, Worthing Rd
Horsham, West Sussex, RH12 1TL, United Kingdom

Electrum [Bitcoin Wallet]
Electrum
63-65 Blvd Massena
Paris, 75013, France

Entropay
Ixaris Systems (Malta) Ltd. dba Entropay
2 Stephen St
London, W1T 1AN, United Kingdom

Expekt Sportsbook
Mangas Gaming Malta Limited dba Expekt Sportsbook
Level 3, Tagliaferro Business Center, High St c/w Gaiety Ln
Sliema, SLM1551, Malta

EveryGame Sportsbook/Casino
CitoPedia N.V. dba EveryGame Sportsbook/Casino
Heelsumstraat 51
Willemstad, Curacao (Netherlands Antilles)

Fabulous Poker
Investments Manager, S.A. dba Fabulouspoker.com
Sabana Sur
San Jose, 10000, Costa Rica

Fairlay
Fairlay LLC
200 Meters norte de la Cruz Roja de Santa Ana, 8vo Piso
San Jose, San Rafael, Costa Rica

Foxbit
Foxbit
Av. Eng. Luis Carlos Berrini, 550; Cidade Moncoes
Sao Paulo, Brazil

FTX
FTX Trading Ltd.
Lower Factory Road, PO Box 990
St. John’s, Antigua and Barbuda

Gala Poker
LC International Limited dba Gala Poker
Ste 6, Atlantic Suites
Gibraltar, Gibraltar

Gate.io
Gate.io
PO Box 31119, Grand Pavilion, Hibiscus Way; 802 W Bay Rd
Grand Cayman KY1-1205, Cayman Islands

Gatehub
GateHub Limited
Level 3, 207 Regent St
London, W1B 3HH, United Kingdom

gbets
Dynamex (Pty) Ltd dba G-bets
PO Box 7383, Westgate
Roodeport, 1734, South Africa

GGPoker
GG International Limited dba GGPoker
8 Upper Dukes Rd
Douglas, IM2 4BA, Isle of Man

Global Poker
VGW GP Limited dba Global Poker
5-7 Matilda Ct, Giuseppe Cali St
Ta’Xbiex, XBX1423, Malta

Goalwin Poker
Merkur Interactive Italia SpA dba Goalwin Poker
Via dei Lavorsatirn 136/138 20092
Cinisello Balsamo, Italy

GTBets
gtbets.eu dba GTBets
support@gtbets.eu
Willemstad, Curacao

Heritage Sports
Heritage Sports
customerservice@heritagesports.com
San Jose, Costa Rica

HitBTC
Hit Tech Solutions Development Ltd dba HitBTC
Ste 15, Oliaji Trade Centre, Francis Rachel St
Victoria, Mahe, Seychelles

Hodlnaut
Hodlnaut Pte Ltd
16 Raffles Quay, #41-01 Hong Leong Bldg
Singapore, 048581, Singapore

Huobi
Huobi Technology Holdings Ltd
Rm 1404-05, 14F, Nan Fung Tower 88
Hong Kong, Hong Kong

Iconomi
Iconomi Ltd
10 Orange St
London, WC2H 7DQ, United Kingdom

Ignition Casino
Lynton Limited dba Ignition Casino
Craig Plaza, 51-55 Fountain St
Belfast, BT1 5EB, United Kingdom

Interwetten
Interwetten Gaming Ltd.
2nd Flr, Global Capital Bldg, Testaferrata St
Ta’Xbiex, XBX1403, Malta

iPoker
Playtech (Cyprus) Limited dba iPoker
Ground Flr, St. George’s Ct, Upper Church St
Douglas, IM1 1EE, Isle of Man

Iron Poker
Universe Entertainment Services Malta Limited dba Iron Poker
Level 3, Valletta Buildings, South St
Valletta, VLT1103, Malta

J88 Poker
J88Ent Ltd dba J88 Poker
Unit 1101, 11th Flr, Tower 1, Enterprise Square, No. 9, Sheung Yuet Rd; Kowloon Bay
Hong Kong, Hong Kong

Jazz Sports
DPT Sports Group dba jazzsports.ag
DPT Building, Pavas
San Jose, Costa Rica

Juicy Stakes Poker
Thinkquick Ltd dba Juicy Stakes Poker
3997 Armory Bldg
Basseterre, St. Kitts (Saint Kitts and Nevis)

Justbet.co
Investments Manager, S.A. dba Justbet.co
Edificio La Colmena
San Jose, Costa Rica

Just Dice
Just-Dice.com
PO Box 0823-03411
Panama City, Panama

KuCoin
KuCoin Co., Limited
20 Science Park Rd
Singapore, Singapore

Ladbrokes
LC International plc
Ste 6, Atlantic Suites
Gibraltar, Gibraltar

Ledn
Ledn (USA) Inc.
700-350 Bay St
Toronto, ON, M5H 2S6, Canada

Libertyslots.lv
Liberty Slots Group dba Libertyslots.lv
support@libertyslots.com
Willemstad, Curacao

Livecoin
Red Velvet Investments Ltd dba Livecoin
help@livecoin.net
Belize City, Belize

LooseLines
DPT Sports Group dba looselines.ag
DPT Building, Pavas
San Jose, Costa Rica

Lowvig
Lowvig.ag
support@lowvig.ag
San Jose, Costa Rica

Lucky99
5Dimes Casino and Sportsbook dba Lucky99.eu
Edificio Equus
San Jose, Costa Rica

Luxon Payments
Luxon Payments Ltd
Cobden Chambers, Pelham St
Nottingham, NG1 2ED, United Kingdom

MarathonBet
MarathonBet.com
Abraham de Veerstraat 9
Willemstad, Curacao

Matchbook
Triplebet Limited dba Matchbook
Inchalla, Le Val
Alderney, GY9 3UL, Channel Islands (Guernsey)

Mercatox
104363744 Ltd dba Mercatox
Mailboxes E.T.C., Peel House 30
Altincham, WA14 2PX, United Kingdom

MuchBetter
MIR Limited UK Ltd dba MuchBetter
Finance House, 20/21 Aviation Way
Southend, Essex, SS2 6UN, United Kingdom

MyBookie.ag
Duranbah Limited N.V. dba MyBookie.ag
7 Abraham de Veerstraat
Willemstad, Curacao (Netherlands Antilles)

Natural8.com
Run Good N.V. dba Natural8.com
9 Abraham de Veerstrat
Willemstad, Curacao (Netherlands Antilles)

NetBet
NetBet Enterprises Ltd dba NetBet
209, Marina Street
Pieta, PTA9041, Malta

Neteller
Paysafe Financial Services Ltd. dba Neteller
Compass House, Vision Park, Chivers Way
Cambridge, CB24 9BZ, United Kingdom

Nexo Financial LLC
Nexo Financial LLC
1 Canada Sq, Level 39, Canary Wharf
London, E14 5AB, United Kingdom

Nitrogen Sports
Nitrogen Sports
support@nitrogensports.eu
San Jose, Costa Rica

Nordic Bet
BML Group Ltd dba NordicBet
Betsson Experience Center, Ta’Xbiex Seafront
Ta’Xbiex, XBX1027, Malta

Noxwin
Galaxy Grouop Ltd dba Noxwin.com
Intershare Chambers
Road Town, Tortola, British Virgin Islands

Oanda Europe
Oanda Europe Limited
Flr 3, 18 St. Swithin’s Ln
London, EC4N 8AD, United Kingdom

Oddsmaker Casino
OddsMaker.ag
support@oddsmaker.ag
Curacao, Curacao (Netherlands Antilles)

OKEx
Aux Cayes FinTech Co. Ltd dba OKEx
Unit 10-02, Level 10, Menara Binjai, No. 2, Jalan Binjai
Kuala Lumpur, 50450, Malaysia

OKPoker
Loto Quebec dba OKPoker
500 Sherbrooke St W
Montreal, QC H3A 3G6 Canada

Pacific Poker
Cassava Enterprises (Gibraltar) Limited dba Pacific Poker
Suite 601-701, Europort Ave
Gibraltar, Gibraltar

PaddyPoker
PBB Counterparty Services Limited dbaPaddyPoker
Triq il-Kappillan Mifsud
St. Venera, SVR1851, Malta

Party Poker
Electra Works dba Party Poker
Suite 6, Atlantic Suites, Europort Ave
Gibraltar, Gibraltar

Pinnacle Sports
Ragnarok Corporation N.V. dba Pinnacle.com
Pletterjweg 43
Willemstad, Curacao (Netherlands Antilles)

Piwi247.com
Asianconnect N.V. dba Piwi247.com
E-Zone Beheer van Engelen N.V., Van Engelenweg 21A
Willemstad, Curacao (Netherlands Antilles)

Planetwin365 Poker
SKS365 Malta, dba Planetwin365 Poker
Corso Vittoria Emanuel 11, 282-284
Rome, 00188, Italy

Players Only
Gaming Ventures Ltd. dba Players Only
60 Nevis St
St. John’s, Antigua (Antigua and Barbuda)

PlayNow
British Columbia Lottery Commission dba PlayNow
74 W Seymour St
Kamloops, BC V2C 1E2 Canada

Poker4u
Olincorp Limited dba poker4u
7, Florints St, Greg Tower, 6th Flr
Nicosia, 1065, Cyprus

Poker770
Mandarin Gaming NV dba Poker770
PO Box 4920
Curacao, Netherlands Antilles (Curacao)

Pokerhost
PH Multitech Curacao N.V. dba Pokerhost
E-Commerce Park, Vredenberg
Willemstad, Curacao, (Netherlands Antilles)

PokerKing
King Enterprises BG Ltd. dba PokerKing
Plaza P.L. Brion Unit 4
Willemstad, Curacao

PokerStars
Rational Intellectual Holdings Limited dba PokerStars
Douglas Bay Complex, King Edward Rd
Onchan, IM3 1DZ Isle of Man

PokerStars.eu
Rational Intellectual Holdings Ltd dba PokerStars.eu
Villa Seminia, 8, Sir Temi Zammit Ave
Ta’Xbiex, XBX1011, Malta

PokerStars.fr
REEL Malta Limited dba PokerStars.fr
Villa Seminia, 8, Sir Temi Zammit Ave
Ta’Xbiex, XBX1011, Malta

Poloniex
Polo Digital Assets, Ltd. dba Poloniex
F20, 1st Floor, Eden Plaza
Eden Island, Seychelles

PPPoker
AceKing Tech Limited dba PPPoker
OMC Offices, Babrow Bldg
The Valley, 2640, Anguilla

PredictIt
PredictIt Europe Limited
6 Agar St
London, WC2N 4HN, United Kingdom

PS3838.com
Ragnarok Corporation dba ps3838.com
Pletterjweg 43
Willemstad, Curacao (Netherlands Antilles)

Red Kings
SkillOnNet Ltd. dba Red Kings
Office 1/5297 Level G, Quantum House, 75 Abata Rigord St
Ta’Xbiex, XBX1120, Malta

Red Stag Casino
DeckMedia.NV
Heelsumstraat 51, E-Commerce Park
Willemstad, Curacao

RedStar Poker
RSP Entertainment N.V. dba RedStar Poker
12 Georgiou Grive Digeni, Stephanie House, Office 101
Nicosia, 3101, Cyprus

Run It Once [Poker]
Run It Once Ltd.
35 Strait St
Valletta, VLT1434, Malta

Skrill (formerly Moneybookers)
Skrill Limited
Floor 27, 25 Canada Square
London, E14 5LQ, United Kingdom

Skybook Sportsbook and Casino
Azure Ventures Limited dba Skybook Sportsbook and Casino
G1, Haven Ct, 5 Library Ramp
Gibraltar, Gibraltar

slots.lv
Lynton Limited dba slots.lv
Craig Plaza, 51-55 Fountain St
Belfast, BT1 5EB, United Kingdom

Smarkets
Smarkets (Malta) Limited
The Hedge Business Center, Level 7, Triq Ir-Rampa ta’ San Giljan
St. Julians, STJ1062, Malta

Sorare
Sorare SAS
5, Avenue du General de Gaulle
a Saint Mande, 94160, France

sportbet.com
5Dimes Casino and Sportsbook dba sportbet.com
Edificio Equus
San Jose, Costa Rica

Sports Interaction
Mohawk Online dba Sports Interaction
2006 Old Malone Rd, PO Box 1539
Kahnawake, QC, J0L 1B0, Canada

Sportsbetting.ag
Blue High House S.A. dba Sportsbetting.ag
Area Bancaria, Avenida Balboa
Panama City, Panama

Sportsbook
Paddy Power Betfair dba sportsbook.eu
Belfield Office Park, Beech Hill Rd
Clonskeagh, Dublin, 4, Ireland

swcpoker
OrangeWebsite.com dba swcpoker (aka Seals With Clubs, swcpoker.eu)
Kapparstigur 7
Reykjavik, Iceland

The Greek
WS Processing Ltd. dba The Greek Sportsbook
#1 Mangrove Way, M.B.F.Z.
Freeport, Montego Bay, Jamaica

Tiger Gaming
Troy Logic Limited dba Tiger Gaming
170, Patar House, Level 1 (Ste A203), Psaila St
Birkirkara, BKR9077, Malta

Titan Poker
Universe Entertainment Services Malta Limited dba Titan Poker
Level 3, Valletta Bldgs, South St
Valletta, VLT1103, Malta

TopBet.eu
TopBet.eu
support@topbet.eu
Manila, Philippines

TransferWise
TransferWise
6th Flr, The Tea Bldg, 56 Shoreditch High St
London, E1 6JJ, United Kingdom

TryLNK.com
TryLNK.com
csd@trylnk.com
Amsterdam, Netherlands

True Poker
BMX Entertainment S.A. dba True Poker
Sabana Sur, Edificio La Colmena Contigo a Grupo Sama
San Jose, Costa Rica

Unibet
Trannel International Ltd. dba Unibet
Level 6, The Centre, Tigne, Point
Sliema, Malta

Vauld
Defi Payments Pte Ltd dba Vauld
80 Raffles Pl, #32-01 UOB Plaza
Singapore, 048624, Singapore

Vietbet
5Dimes Casino and Sportsbook dba Eurobet
Edificio Equus, San Pedro de Montes de Oca, 7mo Piso
San Jose, Costa Rica

WagerWeb
WagerWeb.ag
support@wagerweb.ag
San Jose, Costa Rica

William Hill
WHG (International) Ltd
6/1 Waterport Place
Gibraltar, Gibraltar

Winamax.fr
Winamax
CS 50746, CEDEX 07
Paris, 75345, France

Winner Poker
Universe Entertainment Service Malta dba Winner Poker
Level 3, Valletta Bldgs, South St
Valletta, VLT 1103, Malta

WPTPoker.com
Electraworks Limited (bwin.party digital entertainment plc) dba WPTPoker
Ste 711, Europort
Gibraltar, Gibraltar

Yobit
Yobit.net
support@yobit.net
Moscow, Russia

Youwager.eu
Dowson Universal Technologies Limited dba Youwager.eu
20 Stuart Ct
Consett, County Durham, DH8 5GA, United Kingdom (hide)

If anyone has additions or corrections to the list feel free to email them to me.

IRS Officially Announces Delay in Reporting Cryptocurrency Transactions on Form 8300

Tuesday, January 16th, 2024

The IRS officially announced today that businesses do not have to report the receipt of digital assets on Form 8300 until the Treasury and the IRS issue regulations implementing the new law.  The IRS officially announced this in Announcement 2024-4.  Per the announcement:

The Treasury Department and the IRS intend to implement section 80603(b)(3) of the Infrastructure Act by publishing regulations specifically addressing the application of section 6050I to digital assets and by providing forms and instructions for reporting that address the inclusion of digital assets. Accordingly, until the Treasury Department and the IRS publish regulations under section 6050I to implement section 80603(b)(3) of the Infrastructure Act, persons engaged in a trade or business who, in the course of that trade or business, receive digital assets or digital assets and other cash in one transaction (or two or more related transactions) will not be required to include those digital assets when determining whether cash received has a value in excess of the $10,000 reporting threshold for purposes of determining if reporting is required under section 6050I with respect to those transactions.  Persons engaged in a trade or business who, in the course of that trade or business, receive cash (other than digital assets) in excess of $10,000 in one transaction (or two or more related transactions) must continue to file an information return under section 6050I with respect to that cash received.

The news release notes that proposed regulations will be issued; a comment period is required by law and a public hearing might be held.  As usual, we await further guidance.

Form 8300, Cryptocurrency, and Gambling: An Update

Monday, January 8th, 2024

Last August I wrote a post noting that as of January 1, 2024 cryptocurrency is considered to be cash for Form 8300 reporting requirements.  Here’s what I wrote last August:

A Twitter/X post from John Reed Stark reminded me about an issue that may soon impact you if you are a professional gambler playing on one of the current US-facing sites such as Ignition or America’s Card Room (ACR).  FINCEN (the Financial Crimes Enforcement Network) Form 8300 requires anyone in business–this includes individuals (sole proprietors), partnerships, LLCs, and corporations–to report cash transactions of more than $10,000.  This law isn’t new, and like almost anything related to money laundering/FINCEN there are draconian penalties for not complying.  What is new is that cryptocurrency is considered “cash” for this purpose under Section 6050I of the Infrastructure Act (which passed in November 2021).  This section of the law takes effect on January 1, 2024.

Form 8300 requires you to inform FINCEN (or the IRS if you’re not subject to electronic filing rules) within 15 days of any transaction of more than $10,000:

“Who must file. Each person engaged in a trade or business who, in the course of that trade or business, receives more than $10,000 in cash in one transaction or in two or more related transactions, must file Form 8300. Any transactions conducted between a payer (or its agent) and the recipient in a 24-hour period are related transactions. Transactions are considered related even if they occur over a period of more than 24 hours if the recipient knows, or has reason to know, that each transaction is one of a series of connected transactions.”

I am receiving a steady stream of questions regarding this, so here’s a primer.

  1. There are two elements needed to have to report cryptocurrency you receive.  You need to (a) be in a trade or business and (b) receive more than $10,000 in cash (or cryptocurrency) in one or more related transactions.  If both elements aren’t there, no reporting is required.
  2. If you are an American professional gambler, you are covered by this rule.
  3. The rule covers only receiving cryptocurrency, not sending cryptocurrency.
  4. It only covers receiving cryptocurrency as part of a trade or business.  Let’s say you purchase $20,000 of cryptocurrency for investing; this generally wouldn’t be covered by the reporting requirements of Form 8300.
  5. Reporting is not required if the transaction occurs entirely outside of the United States.

So let’s look at a couple typical examples.

  1. You are a professional gambler residing in the United States.  You cash out from an online gambling site based in Costa Rica and receive $10,500: $5,000 as a bank transfer and $5,500 of cryptocurrency.  The transaction must be reported on Form 8300.
  2. You are a professional gambler.  You are “staked” (backed) by June.  She sends you a personal check for $20,000 to stake you.  Personal checks are specifically exempt from Form 8300 filing requirements.  “Cash does not include…[p]ersonal checks drawn on the account of the writer, a cashier’s check, bank draft, traveler’s check or money order with a face value of more than $10,000.”  (Similarly, wire transfers are not reportable on Form 8300.)

From the instructions of Form 8300 it is absolutely doable to report a cashout from an online gambling site such as America’s Cardroom.  You do not need to include a taxpayer identification number for a non-US business: “You are not required to provide the TIN of a…foreign organization that…[d]oes not have an office or place of business, or a fiscal or paying agent, in the United States.”  You may need to put a comment on Form 8300 (at the bottom of page 2) to note this. You likely also need to comment that the “cash” received was (say) Bitcoin.

Of course, we’re dealing with the federal government so there are issues.  While Form 8300 was revised as of  December 31st, the revision doesn’t include a place for cryptocurrency.  While it’s possible to report a business sending cash, the reporting always asks for the individual who sent it.  Well, that won’t be doable for most cryptocurrency transactions–again, a comment will be needed.

I suspect this will be a mess as FinCEN hasn’t thought this through; indeed, I think they’re just superficially aware of this issue and are really concentrating on BOI reporting.   In any case, I’ll see what comes of yet another government mandate.

 

Form 8300, Cryptocurrency, and Gambling

Wednesday, August 9th, 2023

A Twitter/X post from John Reed Stark reminded me about an issue that may soon impact you if you are a professional gambler playing on one of the current US-facing sites such as Ignition or America’s Card Room (ACR).  FINCEN (the Financial Crimes Enforcement Network) Form 8300 requires anyone in business–this includes individuals (sole proprietors), partnerships, LLCs, and corporations–to report cash transactions of more than $10,000.  This law isn’t new, and like almost anything related to money laundering/FINCEN there are draconian penalties for not complying.  What is new is that cryptocurrency is considered “cash” for this purpose under Section 6050I of the Infrastructure Act (which passed in November 2021).  This section of the law takes effect on January 1, 2024.

Form 8300 requires you to inform FINCEN (or the IRS if you’re not subject to electronic filing rules) within 15 days of any transaction of more than $10,000:

Who must file. Each person engaged in a trade or business who, in the course of that trade or business, receives more than $10,000 in cash in one transaction or in two or more related transactions, must file Form 8300. Any transactions conducted between a payer (or its agent) and the recipient in a 24-hour period are related transactions. Transactions are considered related even if they occur over a period of more than 24 hours if the recipient knows, or has reason to know, that each transaction is one of a series of connected transactions.

This would include deposits onto gambling websites and withdrawals.  It would include two $5,500 transactions if you deliberately split your withdrawal into two transactions or if the gambling website splits the transaction into two.  (If you are outside of the United States when the entirety of the transaction occurs you are generally exempt.)

Today’s form doesn’t have a place for cryptocurrency, but I would expect that to be remedied by the end of the year (the last version of the form is dated August of 2014).  Form 8300 can be paper-filed or electronically filed on the BSA efile system.  (NOTE: Beginning January 1, 2024, if you are required to efile other information returns such as W-2s or 1099s, you will be required to efile Form 8300.)

While efforts exist in Congress to repeal the new Section 6050I, it’s highly unlikely these efforts will come to fruition.  Indeed, very little of substance has come out of this Congress; given the political divide in the country, expect this law to be in force in five months.  If you’re a professional gambler doing large cryptocurrency transactions (or, for that matter any business that accepts cryptocurrency) you will have more work ahead of you in the new year.

 

The Real Winners of the 2023 World Series of Poker

Tuesday, July 18th, 2023

Yesterday afternoon, the 2023 Main Event of the World Series of Poker concluded. A record 10,043 entrants ponied up the $10,000 buy-in to the event leading to a prize pool of $93,399,900 (the $7,030,100 difference is the funds kept by Caesars for running the event). We focus on the nine-handed final table, but 1,507 received winnings from the prize pool; a minimum cash was worth $15,000. The winner received a whopping $12.1 million; however, did he get to keep it all?

One important note: I do need to point out that many of the players in the tournament were “backed.” Poker tournaments have a high variance (luck factor). Thus, many tournament players sell portions of their action to investors to lower their risk (and/or “swap” action with other entrants). It is quite likely that most (if not all) of the winners were backed (or had swaps) and will, in the end, only enjoy a portion of their winnings. I ignore backing and swaps in this analysis (because the full details are rarely publicized). Now, on to the winners.

Congratulations to Daniel Weinman, a professional poker player from Atlanta. On the final hand, Steven Jones, the runner-up, raised and Mr. Weinman called. On the flop of J-5-2, Mr. Weinman checked, Mr. Jones made a continuation bet, and Mr. Weinman raised with Mr. Jones calling. The turn came a 4, Mr. Weinman bet again, Mr. Jones raised all-in (after a four minute deliberation), and Mr. Weinman called in less than 30 seconds. Both players had a pair of Jacks (Mr. Weinman held K-J while Mr. Jones held J-8). Mr. Jones needed an eight on the river to win the hand, but the river was an Ace giving Mr. Weinman the championship. First place was a cool $12.1 Million. Mr. Weinman owes federal and state income tax and self-employment tax on his winnings. I estimate he will pay $4,831,195 to the IRS and $690,777 to the Georgia Department of Revenue (45.64% lost to taxes).

Second place went to the aforementioned Steven Jones. Mr. Jones, a real estate broker from Scottsdale, Arizona, earned $6.5 million for finishing second. An amateur gambler, Mr. Jones avoids self-employment tax but does owe income tax to Arizona. I estimate he will owe $2,364,616 to the IRS and $193,700 to the Arizona Department of Revenue (taxes took 39.36% of his winnings).

In third place was Adam Walton of nearby Henderson. Mr. Walton was eliminated when his pair of eights ran into Daniel Weinman’s pair of aces. Mr. Walton, a professional poker player, earned $4 million for his finish. As a Nevada resident, he avoids state income tax. However, he does owe federal income tax and self-employment tax. I estimate he will pay $1,557,986 (38.95%) in tax to the IRS.

Jan-Peter Jachtmann, a marketing manager and publisher of PokerBlatt in Germany, finished fourth for $3,000,000. Formerly a pot-limit Omaha specialist (Mr. Jachtmann won a WSOP event in that game in 2012), he’s likely to play quite a bit more no-limit hold’em in the future. On his final hand, his King-Queen ran into the pocket Aces of Adam Walton; the board gave Mr. Jachtmann no help and he was eliminated. The US-Germany Tax Treaty exempts gambling from withholding. Fortunately for Mr. Jachtmann, Germany taxes only professional poker players. Germany’s Rennwett und Lotteriesteuer (which dates to 1922!) exempts winnings of players (except for professionals). So as long as Mr. Jachtmann keeps his gambling as a hobby he won’t have to pay tax on it to Germany.

Finishing in fifth place for $2,400,000 was Ruslan Prydryk of Lungansk, Ukraine. Mr. Prydryk, a lawyer by training, plays poker part-time. He moved all-in with Queen-Ten, but ran into an Ace-Jack from his opponent. It didn’t help that the opponent also flopped two-pair. The US and Ukraine do have a tax treaty, and it exempts gambling so the IRS gets nothing. Ukraine does tax gambling, though; he faces a 19.5% flat tax rate. He ends up owing an estimated $456,000 (or 16,751,816 hryvnia) to the State Tax Service of Ukraine.

The sixth place finisher was Dean Hutchison, a professional poker player from Glasgow, Scotland. Mr. Hutchison’s long run in the main event ended when his pocket fives ran into the pocket sevens of Jan-Peter Jachtmann (and he received no help from the community cards). Mr. Hutchison earned $1,850,000 for his deep run in the event. Better still, he benefits from two quite favorable tax situations. First, the tax treaty between the United States and the United Kingdom exempts gambling from withholding. Second, the United Kingdom doesn’t tax gambling–even for professional gamblers. It’s always nice when your after-tax income is legally the same as your pre-tax income.

Toby Lewis, a professional poker player from Southampton, England finished in seventh place. Mr. Lewis was perhaps the most accomplished tournament player (along with Daniel Weinman) who made the final table. He maneuvered his short starting stack up two places to finish in seventh for $1,425,000. Like the aforementioned Mr. Hutchison, Mr. Lewis gets to keep all of his winnings thanks to the US-UK Tax Treaty and UK law.

In eighth place was Juan Maceiras of La Caruna, Spain. The Spanish poker professional entered the final table in fifth place but could never get anything going. Still, $1,125,000 is a good consolation prize. The US-Spain Tax Treaty exempts his winnings from withholding by the IRS. However, Spain does tax gambling. Indeed, Spain’s Agencia Tributeria is well known in poker circles as looking for every penny it can find (it has gone after winnings of non-Spaniards who cashed in poker tournaments held in Spain). Earlier this year, the Agencia Tributeria ruled that professional poker players are professional sportsmen; that means Spain gets to withhold tax on non-Spaniards winnings in Spain. For Mr. Maceiras, he will be in Spain’s top tax bracket of 47% (on income of €300,000 or more). Overall, I estimate Mr. Maceiras will owe $528,750 (€523,400) to Agencia Tributeria; he pays the highest percentage of tax of any of the final table participants.

The ninth place finisher was Daniel Holzner. Mr. Holzner is an apple farmer in Italy (yes, he really is) and received the entry as a birthday present for turning 30. He is quoted by PokerNews, “…I guess I have to make a really big, big, big party for them, all of them.” He’ll have plenty of funds for that party. His ninth place finished earned him $900,000. The US-Italy Tax Treaty exempts Italians from withholding. However, he will be taxed in Italy. (Gambling winnings in Italy and the European Union are exempt from Italian tax.) I estimate he will owe $387,000 to Italy’s Agenzia delle Entrate (a high 43% tax rate).

Here’s a table summarizing the tax bite:

Amount won at Final Table $33,300,000
Tax to IRS $8.753.797
Tax to Georgia Department of Revenue $690,777
Tax to Agencia Tributeria (Spain) $528,750
Tax to State Tax Service (Ukraine) $456,000
Tax to Agenzia delle Entrate (Italy) $387,000
Tax to Arizona Department of Revenue $193,700
Total Tax $11,010,024

That means 33.06% of the winnings at the final table goes toward taxes.

Here’s a second table with the winners sorted by their estimated take-home winnings:

Winner Before-Tax Prize After-Tax Prize
1. Daniel Weinman $12,100,000 $6,578,028
2. Steven Jones $6,500,000 $3,941,684
4. Jan-Peter Jachmann $3,000,000 $3,000,000
3. Adam Walton $4,000,000 $2,442,014
5. Ruslan Prydryk $2,400,000 $1,944,000
6. Dean Hutchison $1,850,000 $1,850,000
7. Toby Lewis $1,425,000 $1,425,000
8. Juan Maceiras $1,125,000 $596,250
9. Daniel Holzner $900,000 $513,000
Totals $33,300,000 $22,289,976

Once again, a player ended up placing higher than his actual finish based on after-tax results. This year, Mr. Jachmann of Germany was the beneficiary of being an amateur gambler. Do note that German professional gamblers don’t get such a good tax result. Indeed, many German professional poker players have moved to Austria (a much more favorable tax situation).

The Internal Revenue Service did not end up with taxes that exceeded the first place winnings; the agency will have to be content with finishing in second place (based on pre-tax prizes) with a haul of just $8,753,797. Still, you can’t say that the IRS didn’t do poorly because the house always wins.

WSOP and Taxes: 2023 Update

Wednesday, May 31st, 2023

The 2023 World Series of Poker (WSOP) began yesterday here in Las Vegas at the Paris and Horseshoe hotels (the hotels are linked). There are also several other tournament series that have either begun or will soon begin at the Venetian, Wynn/Encore, Aria, MGM Grand, Golden Nugget, and Orleans hotels. Very little has changed from 2018, but I am updating the post I did then with some new information.

In 2022, the WSOP was unable to issue Individual Taxpayer Identification Numbers (ITINs).  The WSOP believes they will soon be able to issue ITINs.  This is a key issue for non-Americans from Tax Treaty countries who don’t already have an ITIN.  Impacted individuals who cash early in the series may want to wait before receiving their winnings until the WSOP officially can issue ITINs.

Good luck to those participating in this year’s WSOP!

And now on to the meat of the post: I’m covering the basics of the tax situation, backing, foreign (non-US) backing, and non-American winners and what they will face with taxes. This post will be somewhat long, so I’m going to break this into sections that you can click on to open. The focus is on tournaments where tax paperwork is issued. I’ve also added a section relating to anti-money laundering (AML) rules.

The Tax Basics

If you win more than $5,000 net you will receive a W-2G (if you’re an American) or a Form 1042-S (if you’re a non-American). If you’re an American and you provide your social security number to the casino, there will be no withholding. If you’re a non-American and you have an ITIN (an Individual Taxpayer Identification Number) and you are from a Tax Treaty country, there will be no withholding. Otherwise there will be tax withheld: 24% for Americans and 30% for non-Americans.

So what are the Tax Treaty Countries? As noted in Publication 515, “Gambling income of residents (as defined by treaty) of the following foreign countries is not taxable by the United States: Austria, Belgium, Bulgaria, Czech Republic, Denmark, Finland, France, Germany, Hungary, Iceland, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Netherlands, Russia, Slovak Republic, Slovenia, South Africa, Spain, Sweden, Tunisia, Turkey, Ukraine, and the United Kingdom.”  (Residents of Malta have a 10% withholding rate.)

But if gambling winnings of a resident of the United Kingdom isn’t subject to tax, why would a casino withhold? Because if there’s no ITIN, a casino must withhold. Most (but not all) casinos still issue ITINs. I go over the ITIN situation below.

Backing by Americans of Americans

Suppose Russ plays in a WSOP event and is backed by Scott. Scott has provided half of Russ’s buyin and Russ has agreed to give Scott 50% of his net winnings. Russ is lucky enough to win $10,000 net, so he will receive tax paperwork from the Paris Hotel and Casino (where the WSOP is played). What should Russ do?

First, before the tournament Russ should collect social security numbers from his backers. The IRS has a form for this: Form W-9. The backer completes the form (including signing it) and provides it to the individual he’s backing (not the IRS). The IRS also has a form, Form 5754, designed specifically for the situation where you have backers. You include the names, addresses, and tax identification numbers (social security numbers or ITINs) of the backers along with their percentage winnings or the exact winnings. The casino is supposed to issue multiple W-2Gs. Unfortunately, the WSOP will not issue multiple W-2Gs even though the instructions to Form 5754 specify that the casino is supposed to follow the form. Indeed, I am unaware of any Las Vegas poker room currently accepting Form 5754. However, it’s still a good idea to have the form completed if you’re playing (it’s additional backup that the IRS could request).

So what should Russ do when he cashes at the WSOP? Russ becomes the casino for paperwork issuing; he must issue his backer(s) paperwork to show their winnings. It’s a fundamental principal of US tax law that everyone pays tax on their income, not anyone else’s. Russ should issue Form 1099-MISC(s) to his backers showing their shares of his winnings. A couple of comments about Form 1099-MISC. First, you issue one 1099-MISC to an individual per type of income per year. Thus, generally you will wait until the end of the year to send out your 1099s. Second, it’s far easier to obtain backers’ tax identification numbers before you pay them. You should make receiving appropriate tax paperwork (W-9 for Americans, W-8BEN for non-Americans) a requirement for your backers to receive their shares of your income. Third, note that Form 1099-MISC cannot be downloaded off the Internet. If you file paper Form 1099-MISCs with the IRS, you must order the forms from the IRS. If you are going to paper-file your Form 1099s, you must also order Form 1096 (this is the cover page that you use to send 1099s to the IRS).

One other key point: Russ needs to maintain a paper trail showing he sent the winnings to Scott.  This can be a cancelled check, wire transfer paperwork, etc.  But what if Russ pays Scott in cash or casino chips?  He needs a signed and dated receipt.

Backing: Non-Americans

 

What happens if an American is backed by an individual from a Tax Treaty country (such as Russia)? Under the US-Russia Tax Treaty, the gambling income of a Russian is not subject to US taxation. Second, what happens if an American is backed by an individual from a non-Tax Treaty country (such as Australia) or from Canada (the US-Canada Tax Treaty mandates withholding)? Finally, what happens if someone from a non-Tax Treaty country or Canada is backed by an American? For all three scenarios, let’s assume I’m entering the main event of the WSOP (the buy-in is $10,000); my backer is paying $5,000 and is receiving 50% of my winnings. I place in the event and win $20,000, so my backer is owed $10,000 (all numbers before withholding).

Scenario #1: US Player Backed by an Individual from a Tax Treaty Country. Let’s assume I’m playing and am backed by Ivan from Russia. I receive a W-2G for $10,000 (my net winnings). It would seem all I have to do is just pay Ivan his $10,000 share of my gross profit, right? Wrong. Even though Ivan is from a Tax Treaty country, paperwork is required or tax must be withheld. Ivan needs to provide you either a Form W-8BEN or a Form W-8ECI. The Form W-8BEN is used to note the benefits of a Tax Treaty. Ivan would complete the form, including his ITIN and note the Article of the Tax Treaty that specifies that there would be no withholding. As long as you receive the completed Form W-8BEN you can then pay Ivan his share. If you pay by cash or casino chips, make sure you get a signed receipt from Ivan acknowledging his receipt of the money.

What if Ivan doesn’t have an ITIN? Then you must withhold at 30% even though he’s exempt from withholding. You would need to complete Form 1042-S and depending on the amount withheld very quickly remit that money using EFTPS to the IRS. (EFTPS is now the only method available for making withholding deposits to the IRS.) Ivan can get the money back by filing a Form 1040NR following year-end. If Ivan has a business operating in the US, he would provide Form W-8ECI with either his Employer Identification Number (EIN) or his ITIN. This will allow you not to withhold to Ivan. Note: Even if no withholding is required a Form 1042-S must be submitted to the IRS.

We can see that even the easy scenario isn’t necessarily that easy.

Scenario #2: US Player Backed by an Individual from a Non-Tax Treaty Country This case is relatively straightforward. Let’s say your backer is Jon from Canada or Australia. (Although Canadians can get some to all of their money back by filing Form 1040NR after year-end, you are required to withhold on their income per the US-Canada Tax Treaty.) You must withhold 30% of their winnings. You would pay him all of his $5,000 investment and 70% of his $5,000 winnings ($3,500) for a total of $8,500. You would complete Form 1042-S with his information and note that $1,500 of his $5,000 of income has been withheld. Depending on the amount withheld, there can be very quick deadlines for remitting that withholding to the IRS; that withheld funds must be remitted using EFTPS.

Scenario #3: Non Tax-Treaty Player Backed by an Individual from the US This is the ugly scenario. Suppose Jon is backed by Russ from the US. Russ isn’t subject to any withholding on his money (he’s a US citizen, after all) and is more than willing to provide a completed Form W-9. Unfortunately, because Caesars will not issue multiple W-2Gs/Form 1042-S’s, all of the $10,000 Jon wins will be subject to withholding. So Jon will receive $17,000 (his $10,000 entry plus $7,000 of his $10,000 in winnings). Jon is left with two bad options. He could pay Russ $3,500 (half of the amount he has won). Russ will rightly be annoyed as he should receive $5,000. Jon has no way of telling the IRS that $1,500 of his tax withheld is for Russ [See Note 1 below]. Alternatively, Jon can pay Russ $5,000 and now he only has $2,000 of his winnings (rather than the $3,500 he should have). That method probably doesn’t appeal to Jon at all. Unfortunately, neither option is palatable to both individuals and these are the only two options available.

There is a solution: Americans should not back individuals from non-Tax Treaty countries. (The better solution, Caesars issuing multiple W-2Gs/1042-S’s, will have to wait until the IRS goes after Caesars on their policy.)

There are some other things that need to be pointed out. The participant will likely have to issue 1099-MISC’s or 1042-S’s to individuals. You probably don’t want everyone to know your social security number. If you’re a professional gambler, there’s a solution: Apply for an EIN. You can do this at no charge online at the IRS website. You must have an EIN if you are going to have to withhold funds. Next, if there’s a possibility you are going to be a withholding agent, you must have both an EIN and an EFTPS account. After you get the EIN, immediately enroll in EFTPS. Your passwords are mailed to you; this takes about 10-21 days from the date you enroll, so get this going now if you are going to be playing in the 2023 WSOP and this applies to you. Third, you can give Caesars a piece of your mind (nicely, though) and let them know about the ridiculousness of their policy. That’s especially true if you’re from Australia and you would like to be backed by an American (or someone from a country with a favorable Tax Treaty with the US).

Non-Americans and ITINs

 

When I wrote this article in 2018, it was very uncertain whether or not casinos would be allowed to issue ITINs. As I noted in the introduction, the WSOP expects to be able to issue ITINs soon.  If you are from a country with a Tax Treaty with the US that covers gambling and are playing in a poker tournament at a different casino, you can (and likely should) check with the casino to see whether or not they issue ITINs. Let’s say you’re from the United Kingdom and are backing Russ. He wins $20,000 at the WSOP ($10,000 of it goes to you) and you don’t want him to withhold $3,000. If you wait to do something until Russ wins the money, he’s going to have to withhold. In that case, you will have to apply for an ITIN and file Form 1040-NR with the IRS the following year. It takes at least two months to receive an ITIN after applying. Form 1040-NR is released around February 1st (of the following year); it takes at least six months to receive a refund after filing Form 1040-NR. The refund is issued as a check mailed to the address on file.

There are three methods available to apply for an ITIN. No matter which method you use you will need to complete Form W-7 and have the required backup documents (generally, your original passport). You can apply by mailing your Form W-7 with backup documents to the IRS. This is generally done with the filing of a tax return. You can provide a prepaid courier envelope to receive back your passport. Your ITIN will be issued in about four to six months. You can also make an appointment at an IRS office. The IRS will review your backup documents for your W-7 and make “certified copies” and forward the W-7 to Austin, Texas (where ITINs are issued). If you have a Tax Treaty reason, you can obtain an ITIN. The last time I checked the wait time to get an appointment here in Las Vegas is six weeks. I was also informed by a local IRS Certified Acceptance Agent that the IRS has not cut them off (yet) from reviewing W-7 paperwork and forwarding paperwork and “certified copies” to Austin. This may be a good method for someone who is in Las Vegas to apply for an ITIN and has a tax treaty reason to obtain an ITIN. Also, if you use a local Certified Acceptance Agent you will not obtain an ITIN immediately; your ITIN will still be mailed to you in a few months. Thus, my strong recommendation for such an individual backing an American is to get your ITIN now!

But what if you already have a valid ITIN and are from a Tax Treaty country? Then there are no issues. You will just let the casino know your ITIN number when you cash. (You may be asked to provide other documentation and/or be asked to complete a Form W-8BEN.)

Anti-Money Laundering Rules

In the United States, casinos are considered financial institutions and must obey anti-money laundering (AML) laws and regulations. These are mostly promulgated by the Financial Crimes Enforcement Network (FinCEN) but some are issued by other federal agencies and regulatory bodies. The basic idea of all these laws is to be able to trace the money. (Do note that I am not an attorney; I’m a tax professional. For those who need professional advice about AML laws, seek an attorney who specializes in this area. This is just a brief summary and absolutely not meant as legal advice.)

Let’s say you have an account at the WSOP, funded by a cash deposit or wire transfer, and you take out $12,000 in casino chips to play in a high-stakes cash game. The cage will file a Currency Transaction Report (CTR) on the transaction. These (generally) aren’t a big issue. You do want to avoid Structuring your transactions. Let’s say instead of taking out $12,000 in one transaction you elect to take out $6,000 in two transactions (separated by an hour). That’s structuring, and that’s a felony. Additionally, a Suspicious Activity Report (SAR) would be issued. At a continuing education seminar a couple of years ago we were told by the head of IRS Criminal Investigation in Las Vegas that they investigate few CTRs but all SARs issued. The solution: Just go big and take out all the money you need at once.

Another area where a poker player can run afoul of the AML rules is by (a) wiring money to one casino, (b) cashing out a significant amount from that casino as casino chips, and (c) going to a second casino and using those chips as a buy-in or for obtaining that casino’s chips. There are multiple issues here. Let’s look at a specific hypothetical example. Ivan wires $50,000 to the Paris casino for the WSOP. Ivan leaves $35,000 on his account at the WSOP, and cashes out $15,000 in chips telling the cage, “I’m going to use these for buying in to big events at the Wynn/Encore.” As far as I know, there’s nothing illegal in Ivan doing this (Ivan is not trying to evade AML rules); however, he’s likely running afoul of the AML policies of the WSOP (Paris Hotel). Casinos want their chips used at their casino, and taking those chips out for use elsewhere almost certainly is against the AML rules that the Paris Casino has adopted and must follow (or they will get in trouble win FINCEN). The solution to this is simple: Wire money to each casino.

[Note 1]: It is likely the IRS would reject a Form 1040NR filed by Jon noting his extra withholding. The IRS won’t understand the issue given that there is no tax treaty issue (say, Jon is from Australia) and say, “Take it up with Caesars.” It’s a classic Catch-22.

Colorado: Let’s Implement a 1207800% Marginal Tax Rate!

Thursday, May 25th, 2023

Consider two taxpayers who enjoy gambling; both are single and residents of Colorado.  Both are amateur gamblers who earn $100,000 of wage income and rent.  Joe Unlucky broke dead even in his gambling, winning $299,000 (using the session method) and losing $299,000.  When he files his 2022 tax returns, he has a federal refund of $3,238 and a Colorado refund of $490.

Larry Lucky fared a little better: He had $301,000 of gambling winnings and $301,000 of gambling losses.  When he files his 2022 tax returns, he has the identical federal refund of $3,238.  However, he owes Colorado a whopping $11,632.  What caused Larry to have a ridiculous marginal tax rate of 606.1% on the additional $2,000 of gross winnings?

For 2022, Colorado implemented a $30,000 reduction in itemized deductions for taxpayers whose Adjusted Gross Income exceeds $400,000 and who itemize their deductions.  (The reduction is $60,000 if married filing jointly.)  Larry faced this; Joe didn’t.  Larry ends up with that 606.1% marginal tax rate on $2,000 of “winnings!”  Remember, Larry broke even so he really didn’t win anything.

I could have made this illustration even more ridiculous.  It truly is a hard cliff: If Joe had $300,000 of wins and losses he would have refunds of $3,238 from the IRS and $490 from Colorado; if Larry had $300,001 of wins and losses he would have the same federal refund of $3,238 but would owe Colorado $11,588.   That’s an insane marginal tax rate of 1,207,800% on the additional dollar of income!

Hard cliffs cause taxpayers to make decisions that are correct for themselves but bad for the economy.  Consider if Larry and Joe had their own businesses, each earning around $400,000 a year.  Assume both have net income of $399,000 right at year-end and have the opportunity for an additional $2,000 of net income.  There is no circumstance where it makes sense for them–if they reside in Colorado–to obtain that income in the year; they would be facing a tax rate of more than 100%.

Proposals like what passed in Colorado sound good, feel good (let’s tax the rich), but end up with perverse economic results.  Hopefully the Colorado legislature will fix this for the future.

Online Gambling and Cryptocurrency Addresses for 2023

Wednesday, February 1st, 2023

[This list has been superceded by the 2024 list.]

If you have one or more foreign financial accounts and you have $10,000 aggregate in those account(s) at any time during 2022, you must file the Report of Foreign Bank and Financial Accounts (the “FBAR”). This is Form 114 from FINCEN. (The IRS and FINCEN now allege that foreign online poker accounts are “casino” accounts that must be reported as foreign financial accounts. The rule of thumb, when in doubt report, applies—especially given the extreme penalties.) You also should consider filing an FBAR if you have $10,000 or more in a non-US Cryptocurrency Exchange.

There’s a problem, though. Most of these entities don’t broadcast their addresses. Some individuals sent email inquiries to one of these gambling sites and received politely worded responses (or not so politely worded) that said that it’s none of your business.

Well, not fully completing the Form 114 can subject you to a substantial penalty. I’ve been compiling a list of the addresses of the online gambling sites. It’s presented below.

FINCEN does not want dba’s; however, they’re required for Form 8938. One would think that two different agencies of the Department of the Treasury would speak the same language…but one would be wrong.

You will see the entries do include the dba’s. Let’s say you’re reporting an account on PokerStars. On the FBAR, you would enter the address as follows:

Rational Intellectual Properties Limited
Douglas Bay Complex, King Edward Rd
Onchan, IM31DZ Isle of Man

Here’s how you would enter it for Form 8938:

Rational Intellectual Properties Limited dba PokerStars
Douglas Bay Complex, King Edward Rd
Onchan, IM3 1DZ Isle of Man

You will also see that on the FBAR spaces in a postal code are removed; they’re entered on Form 8938. You can’t make this stuff up….

Finally, I no longer have an address for Bodog. If anyone has a current mailing address, please leave it in the comments or email me with it.

Foreign cryptocurrency exchanges with just cryptocurrency do not have to be reported on the FBAR. However, if the account holds anything else (such as ‘fiat’ currency like US dollars, Euros, etc.) the account is reportable.

There is no dispute, though, about reporting foreign cryptocurrency exchanges on Form 8938: They must be reported on Form 8938 (if you have a Form 8938 filing requirement).

Note: This list is presented for informational purposes only. It is believed accurate as of February 1, 2023. However, I do not take responsibility for your use of this list or for the accuracy of any of the addresses presented on the list.

The list is in the cut text below.

The list is in alphabetical order by the common name (not the legal name) of the gambling site. An entry is:

Common Name
Legal Name
Address
City, State/Territory, Postal Code, Country

Note that not all entities have states/territories or postal codes.

IMPORTANT: When reporting on Form 114, the dba’s are not included. When reporting on Form 8938, the dba’s are included.

10Bet
Ocean Star Limited dba 10bet.com
Dragonara Business Center, 5th Flr, Dragonara Rd
St. Julians, STJ3141, Malta

12Bet (except U.K.)
Pacific Sea Marketing International Ltd. dba 12bet.com
MillMall, Ste 6, Wickhams Cay 1, PO Box 3085
Road Town, Tortola, British Virgin Islands

12Bet (U.K.)
TGP Europe Limited dba 12bet.uk
22A Castle St
Douglas, IM1 2EZ, Isle of Man

188Bet
Cube Limited dba 188bet
Ground Floor, St. George’s Court, Upper Church St
Douglas, IM1 1EE, Isle of Man

5dimes
5Dimes Casino and Sportsbook
Edificio Equus
San Jose, Costa Rica

888poker (except U.K.)
Virtual Digital Services Limited dba 888 Poker
Level G, Quantum House; 75, Abate Rigord St
Ta’Xbiex, XBX1120, Malta

888poker (U.K.)
888 UK Limited dba 888 Poker
Ste 601-701, Europort
Gibraltar, Gibraltar

AA Poker
Memoriki Limited dba AA Poker
18/F, Star Centre, 35 Hung To Rd, Kwun Tong, Kowloon
Hong Kong, Hong Kong

America’s Cardroom
BMX Entertainment S.A. dba America’s Cardroom
Sabana Sur, Edificio La Colmena Contigo a Grupo Sama
San Jose, Costa Rica

Asianconnect88
Asianconnect N.V. dba Asianconnect88
E-Zone Beheer van Engelen N.V., Van Engelenweg 21A
Willemstad, Curacao (Netherlands Antilles)

BestPoker
Best Global N.V. dba Best Poker
BS Building, Level 1, Triq Il-Mosta,
Lija, LJA 9012, Malta

Bet365
Bet365
Hillside, Festival Way, Stoke-on-Trent
Staffordshire, ST1 5SH, United Kingdom

Betanysports Casino and Sportsbook
Betanysports Casino and Sportsbook
Edificio Equus
San Jose, Costa Rica

BetCaliente
Tecnologia en Entretenmiente Caliplay S.A.P.I. DE RL DE CV dba BetCaliente
Avenida Cententario Modulo 4 Parte
Tijuana, BCN 22010 Mexico

Betclic
Managas Gaming Malta Limited dba Betclic
Level 3, Tagliaferro Business Center; High St c/w Gaiety Ln
Sliema, SLM1551, Malta

Betcoin.ag
Global Limiting Holding EOOD dbaBetcoin.ag
Nikola Vaptsarov Blvd
Sofia, Bulgaria

BetCris
TV Global Enterprises Ltd dba BetCris
Villa Seminia, 8 Sir Temi Zammit Ave
Ta’Xbiex, XBX1011 Malta

BETDAQ
LC International Limited dba BETDAQ
Ste 6, Atlantic Suites
Gibraltar, Gibraltar

BETDSI
Diamond Sportsbook International dba BETDSI
Santa Ana
San Jose, Costa Rica

Betfair
PBB Counterparty Services Limited dba Betfair
Triq il-Kappillan Mifsud
St. Venera, SVR1851, Malta

Betfred
Petfre (Gibraltar) Limited
5/2 Waterfront Place
Gibraltar, Gibraltar

Betmost Poker
WHG (International) Limited dba Betmost Poker
6/1 Waterfront Place
Gibraltar, Gibraltar

Betnow.eu
Betnow.eu
14 Garrick St
London, WC2E 9SB, United Kingdom

Betonline
BLS International dba Betonline.ag
cs@betonline.ag
Panama City, Panama

BetPhoenix
International Radical Investment S.A. dba BetPhoenix
San Jose Paseo Colon, Condomino 6-30, Torre A, Apartamento 1201
San Jose, Costa Rica

Betsafe
BML Group Ltd Limited dba Betsafe Poker
Betsson Experience Center, Ta’Xbiex Seafront
Ta’Xbiex, XBX1027, Malta

Bettson
BML Group Ltd dba Bettson
Betsson Experience Center, Ta’Xbiex Seafront
Ta’Xbiex, XBX1027, Malta

BetUS
Firepower Trading Ltd dba BetUS
Anthinodorou, 3 Dasoupoll, Strovolos
Nicosia, 2025, Cyprus

betusa.ag
Online Management Services dba betusa.ag
Jasmine Ct, Ste 17, Friar’s Hill Rd
St. Johns, Antigua

BetVictor
Victor Chandler International Ltd dba BetVictor
Ste 23, Portland House, Glacis Rd
Gibraltar, Gibraltar

Binance
Binance Marketing Services Limited
C85602 Melita Ct, Level 3, Triq Giusseppe Cali
Ta’Xbiex, XBX1420, Malta

Bitfinex (non-US users)
BFXNA Inc dba Bitfinex
Ste 13/F, 1308 Bank of America Tower, 12 Harcourt Rd, Central
Hong Kong, Hong Kong

Bitfinex (US users)
Finex Inc. dba Bitfinex
Chaucer Group Limited, 10 Lower Thames
London, E3R 6E14, United Kingdom

BitMax.io
BitMax.io
114 Lavender St, #09-88, Ct Hub 2
Singapore, 338729, Singapore

BitMex
100x Grouop dba BitMex
Second Flr, Capital City, Independence Ave, PO Box 1008
Victoria, Mahe, Seychelles

Bitrue
Bitrue Singapore Pte. Ltd.
73 Upper Paya Lebar Rd, #06-01C, Centro Bianco
Singapore, 534818, Singapore

Bitstamp
Bitstamp Ltd.
5 New Street Square
London, EC4A 3TW, United Kingdom

Black Chip Poker
BMX Entertianment S.A.
Sabana Sur, Edificio La Colmena Contigo a Grupo Sama
San Jose, Costa Rica

Blockchain
Blockchain.info
Rue de Merl, 741, Rue Phillipell
Luxembourg, 2340, Luxembourg

Bluetrade.com
Bleu Digital Enterprises Ltd
527, St. Paul’s St
St. Paul’s Bay, Malta

Bodog
Bodog
service@bodog.eu
Manila, Philippines

Bookmaker.eu
Costa Rica International Sports dba Bookmaker.eu
Edificio La Colmena; 75m W Contraloria de la Sabana Sur
San Jose, Costa Rica

Bovada
Lynton Limited Ltd dba Bovada
Craig Plaza, 51-55, Fountain St
Belfast, BT1 5EB, United Kingdom

Boylesports
Boylesports Ltd
Finnabair Industrial Estate, Dundalk
County Louth, Ireland

Bwin
ElectraWorks Limited dba BWIN
Ste 6, Atlantic Suites, Europort Ave
Gibraltar, Gibraltar

Cafe Casino
Lynton Limited dba Cafe Casino
Craig Plaza, 51-55 Fountain St
Belfast, BT1 5EB United Kingdom

Carbon Poker
PDC Global Collections Ltd dba Carbon Poker
19/21 Circular Rd
Douglas, Isle of Man

CaribSports
Carib International Entertainment Ltd dba CaribSports
35 New Rd
Belize City, Belize

Cashpoint
Cashpoint (Malta) Ltd.
Level 1, Salvu Psaila St
Birkirkara, BKR9077, Malta

Casino77
Mandarin Gaming NV dba Casino 77
Soho Office 3A, Edge Water Complex, Elia Zammit St
St. Julians, Malta

Celeb Poker
Wizplay OS (Cyprus) Limited dba Celeb Poker
Flat 22, 6 Tassou Papadopolou St
Agios Dometios, Nicosia, 2372, Cyprus

Celsius Network Limited
Celsius Network Limited
The Harley Bldg, 77-79 New Cavendish St
London, W1W 6XB, United Kingdom

CEX
CEX.io Ltd
24th Flr, One Canada Square, Canary Wharf
London, E14 5AB, United Kingdom

Click and Buy
Click and Buy International Ltd
6-9 Cynthia St
London, N1 9JF United Kingdom

Cloudbet
Halcyon Super Holdings BV dba Cloudbet
Pareraweg 45
Willemstad, Curacao

CoinEgg Ltd
CoinEgg Ltd
38 Hunstanton Ave
Birmingham, B17 8TA, United Kingdom

CoinLoan
CoinLoan
Lastekodu 25-38
Tallinn, Estonia

Coinmate
Confirmo Ltd. dba Coinmate
The Shard Floor 24/25, 26 London Bridge St
London, SE1 95G, United Kingdom

ComeOn! Poker
Co-Gaming Limited dba ComeOn! Poker
3rd Flr, Spinola Park, Tirq Mikiel Ang Borg
St. Julians, SPK1000, Malta

Coral Poker
Gala Interactive (Gibraltar) Ltd dba Coral Poker
Ste 6, Atlantic Suites
Gibraltar, Gibraltar

Crypto.com
Foris DAX Asia Pte. Ltd. dba crypto.com
#25-01, 1 Raffles Quay, North Tower
Singapore, 048583, Singapore

Crypto.games
MuchGaming B.V. dba crypto.games
Fransche Bloemweg 4
Willemstad, Curacao

CryptoPay
CryptoPay
WeWork Bldg, 12 Hammersmith Grove
London, W6 7AP, United Kingdom

CurrencyFair
CurrencyFair Ltd
Colm House, 91 Pembroke Rd
Ballsbridge, Dublin, Ireland

Dafabet
Bayvieew Technologies Ltd dba Dafabet
RCBC Plaza, Makati
Cagayan Valley, Philippines

Diamond Sportsbook
Diamond Sportsbook International dba BETDSI
Santa Ana
San Jose, Costa Rica

DuckDice.io
Sabant B.V dba DuckDice
Heelsumstraat 51, E-Commercepark Unit 102
Willemstad, Curacao

ecoPayz
PSI-Pay Ltd dba ecoPayz
Afon House, Worthing Rd
Horsham, West Sussex, RH12 1TL, United Kingdom

Electrum [Bitcoin Wallet]
Electrum
63-65 Blvd Massena
Paris, 75013, France

Entropay
Ixaris Systems (Malta) Ltd. dba Entropay
2 Stephen St
London, W1T 1AN, United Kingdom

Expekt Sportsbook
Mangas Gaming Malta Limited dba Expekt Sportsbook
Level 3, Tagliaferro Business Center, High St c/w Gaiety Ln
Sliema, SLM1551, Malta

EveryGame Sportsbook/Casino
CitoPedia N.V. dba EveryGame Sportsbook/Casino
Heelsumstraat 51
Willemstad, Curacao (Netherlands Antilles)

Fabulous Poker
Investments Manager, S.A. dba Fabulouspoker.com
Sabana Sur
San Jose, 10000, Costa Rica

Fairlay
Fairlay LLC
200 Meters norte de la Cruz Roja de Santa Ana, 8vo Piso
San Jose, San Rafael, Costa Rica

Foxbit
Foxbit
Av. Eng. Luis Carlos Berrini, 550; Cidade Moncoes
Sao Paulo, Brazil

FTX
FTX Trading Ltd.
Lower Factory Road, PO Box 990
St. John’s, Antigua and Barbuda

Gala Poker
LC International Limited dba Gala Poker
Ste 6, Atlantic Suites
Gibraltar, Gibraltar

Gate.io
Gate.io
PO Box 31119, Grand Pavilion, Hibiscus Way; 802 W Bay Rd
Grand Cayman KY1-1205, Cayman Islands

Gatehub
GateHub Limited
Level 3, 207 Regent St
London, W1B 3HH, United Kingdom

gbets
Dynamex (Pty) Ltd dba G-bets
PO Box 7383, Westgate
Roodeport, 1734, South Africa

GGPoker
GG International Limited dba GGPoker
8 Upper Dukes Rd
Douglas, IM2 4BA, Isle of Man

Global Poker
VGW GP Limited dba Global Poker
5-7 Matilda Ct, Giuseppe Cali St
Ta’Xbiex, XBX1423, Malta

Goalwin Poker
Merkur Interactive Italia SpA dba Goalwin Poker
Via dei Lavorsatirn 136/138 20092
Cinisello Balsamo, Italy

GTBets
gtbets.eu dba GTBets
support@gtbets.eu
Willemstad, Curacao

Heritage Sports
Heritage Sports
customerservice@heritagesports.com
San Jose, Costa Rica

HitBTC
Hit Tech Solutions Development Ltd dba HitBTC
Ste 15, Oliaji Trade Centre, Francis Rachel St
Victoria, Mahe, Seychelles

Hodlnaut
Hodlnaut Pte Ltd
16 Raffles Quay, #41-01 Hong Leong Bldg
Singapore, 048581, Singapore

Huobi
Huobi Technology Holdings Ltd
Rm 1404-05, 14F, Nan Fung Tower 88
Hong Kong, Hong Kong

Iconomi
Iconomi Ltd
10 Orange St
London, WC2H 7DQ, United Kingdom

Ignition Casino
Lynton Limited dba Ignition Casino
Craig Plaza, 51-55 Fountain St
Belfast, BT1 5EB, United Kingdom

Intertops
International Gaming & Entertainment Ltd dba Intertops
PO Box W427, Teledome bldg, Old Parham Rd
St. John’s, Antigua & Barbuda

Interwetten
Interwetten Gaming Ltd.
2nd Flr, Global Capital Bldg, Testaferrata St
Ta’Xbiex, XBX1403, Malta

iPoker
Playtech (Cyprus) Limited dba iPoker
Ground Flr, St. George’s Ct, Upper Church St
Douglas, IM1 1EE, Isle of Man

Iron Poker
Universe Entertainment Services Malta Limited dba Iron Poker
Level 3, Valletta Buildings, South St
Valletta, VLT1103, Malta

J88 Poker
J88Ent Ltd dba J88 Poker
Unit 1101, 11th Flr, Tower 1, Enterprise Square, No. 9, Sheung Yuet Rd; Kowloon Bay
Hong Kong, Hong Kong

Jazz Sports
DPT Sports Group dba jazzsports.ag
DPT Building, Pavas
San Jose, Costa Rica

Juicy Stakes Poker
Thinkquick Ltd dba Juicy Stakes Poker
3997 Armory Bldg
Basseterre, St. Kitts (Saint Kitts and Nevis)

Justbet.co
Investments Manager, S.A. dba Justbet.co
Edificio La Colmena
San Jose, Costa Rica

Just Dice
Just-Dice.com
PO Box 0823-03411
Panama City, Panama

KuCoin
KuCoin Co., Limited
20 Science Park Rd
Singapore, Singapore

Ladbrokes
LC International plc
Ste 6, Atlantic Suites
Gibraltar, Gibraltar

Ledn
Ledn (USA) Inc.
700-350 Bay St
Toronto, ON, M5H 2S6, Canada

Libertyslots.lv
Liberty Slots Group dba Libertyslots.lv
support@libertyslots.com
Willemstad, Curacao

Livecoin
Red Velvet Investments Ltd dba Livecoin
help@livecoin.net
Belize City, Belize

LooseLines
DPT Sports Group dba looselines.ag
DPT Building, Pavas
San Jose, Costa Rica

Lowvig
Lowvig.ag
support@lowvig.ag
San Jose, Costa Rica

Lucky99
5Dimes Casino and Sportsbook dba Lucky99.eu
Edificio Equus
San Jose, Costa Rica

Luxon Payments
Luxon Payments Ltd
Cobden Chambers, Pelham St
Nottingham, NG1 2ED, United Kingdom

MarathonBet
MarathonBet.com
Abraham de Veerstraat 9
Willemstad, Curacao

Matchbook
Triplebet Limited dba Matchbook
Inchalla, Le Val
Alderney, GY9 3UL, Channel Islands (Guernsey)

Mercatox
104363744 Ltd dba Mercatox
Mailboxes E.T.C., Peel House 30
Altincham, WA14 2PX, United Kingdom

MuchBetter
MIR Limited UK Ltd dba MuchBetter
Finance House, 20/21 Aviation Way
Southend, Essex, SS2 6UN, United Kingdom

MyBookie.ag
Duranbah Limited N.V. dba MyBookie.ag
7 Abraham de Veerstraat
Willemstad, Curacao (Netherlands Antilles)

Natural8.com
Run Good N.V. dba Natural8.com
9 Abraham de Veerstrat
Willemstad, Curacao (Netherlands Antilles)

NetBet
NetBet Enterprises Ltd dba NetBet
209, Marina Street
Pieta, PTA9041, Malta

Neteller
Paysafe Financial Services Ltd. dba Neteller
Compass House, Vision Park, Chivers Way
Cambridge, CB24 9BZ, United Kingdom

Nexo Financial LLC
Nexo Financial LLC
1 Canada Sq, Level 39, Canary Wharf
London, E14 5AB, United Kingdom

Nitrogen Sports
Nitrogen Sports
support@nitrogensports.eu
San Jose, Costa Rica

Nordic Bet
BML Group Ltd dba NordicBet
Betsson Experience Center, Ta’Xbiex Seafront
Ta’Xbiex, XBX1027, Malta

Noxwin
Galaxy Grouop Ltd dba Noxwin.com
Intershare Chambers
Road Town, Tortola, British Virgin Islands

Oanda Europe
Oanda Europe Limited
Flr 3, 18 St. Swithin’s Ln
London, EC4N 8AD, United Kingdom

Oddsmaker Casino
OddsMaker.ag
support@oddsmaker.ag
Curacao, Curacao (Netherlands Antilles)

OKEx
Aux Cayes FinTech Co. Ltd dba OKEx
Unit 10-02, Level 10, Menara Binjai, No. 2, Jalan Binjai
Kuala Lumpur, 50450, Malaysia

OKPoker
Loto Quebec dba OKPoker
500 Sherbrooke St W
Montreal, QC H3A 3G6 Canada

Pacific Poker
Cassava Enterprises (Gibraltar) Limited dba Pacific Poker
Suite 601-701, Europort Ave
Gibraltar, Gibraltar

PaddyPoker
PBB Counterparty Services Limited dbaPaddyPoker
Triq il-Kappillan Mifsud
St. Venera, SVR1851, Malta

Party Poker
Electra Works dba Party Poker
Suite 6, Atlantic Suites, Europort Ave
Gibraltar, Gibraltar

Pinnacle Sports
Ragnarok Corporation N.V. dba Pinnacle.com
Pletterjweg 43
Willemstad, Curacao (Netherlands Antilles)

Piwi247.com
Asianconnect N.V. dba Piwi247.com
E-Zone Beheer van Engelen N.V., Van Engelenweg 21A
Willemstad, Curacao (Netherlands Antilles)

Planetwin365 Poker
SKS365 Malta, dba Planetwin365 Poker
Corso Vittoria Emanuel 11, 282-284
Rome, 00188, Italy

Players Only
Gaming Ventures Ltd. dba Players Only
60 Nevis St
St. John’s, Antigua (Antigua and Barbuda)

PlayNow
British Columbia Lottery Commission dba PlayNow
74 W Seymour St
Kamloops, BC V2C 1E2 Canada

Poker4u
Olincorp Limited dba poker4u
7, Florints St, Greg Tower, 6th Flr
Nicosia, 1065, Cyprus

Poker770
Mandarin Gaming NV dba Poker770
PO Box 4920
Curacao, Netherlands Antilles (Curacao)

Pokerhost
PH Multitech Curacao N.V. dba Pokerhost
E-Commerce Park, Vredenberg
Willemstad, Curacao, (Netherlands Antilles)

PokerKing
King Enterprises BG Ltd. dba PokerKing
Plaza P.L. Brion Unit 4
Willemstad, Curacao

PokerStars
Rational Intellectual Holdings Limited dba PokerStars
Douglas Bay Complex, King Edward Rd
Onchan, IM3 1DZ Isle of Man

PokerStars.eu
Rational Intellectual Holdings Ltd dba PokerStars.eu
Villa Seminia, 8, Sir Temi Zammit Ave
Ta’Xbiex, XBX1011, Malta

PokerStars.fr
REEL Malta Limited dba PokerStars.fr
Villa Seminia, 8, Sir Temi Zammit Ave
Ta’Xbiex, XBX1011, Malta

Poloniex
Polo Digital Assets, Ltd. dba Poloniex
F20, 1st Floor, Eden Plaza
Eden Island, Seychelles

PPPoker
AceKing Tech Limited dba PPPoker
OMC Offices, Babrow Bldg
The Valley, 2640, Anguilla

PredictIt
PredictIt Europe Limited
6 Agar St
London, WC2N 4HN, United Kingdom

PS3838.com
Ragnarok Corporation dba ps3838.com
Pletterjweg 43
Willemstad, Curacao (Netherlands Antilles)

Red Kings
SkillOnNet Ltd. dba Red Kings
Office 1/5297 Level G, Quantum House, 75 Abata Rigord St
Ta’Xbiex, XBX1120, Malta

Red Stag Casino
DeckMedia.NV
Heelsumstraat 51, E-Commerce Park
Willemstad, Curacao

RedStar Poker
RSP Entertainment N.V. dba RedStar Poker
12 Georgiou Grive Digeni, Stephanie House, Office 101
Nicosia, 3101, Cyprus

Run It Once [Poker]
Run It Once Ltd.
35 Strait St
Valletta, VLT1434, Malta

Skrill (formerly Moneybookers)
Skrill Limited
Floor 27, 25 Canada Square
London, E14 5LQ, United Kingdom

Skybook Sportsbook and Casino
Azure Ventures Limited dba Skybook Sportsbook and Casino
G1, Haven Ct, 5 Library Ramp
Gibraltar, Gibraltar

slots.lv
Lynton Limited dba slots.lv
Craig Plaza, 51-55 Fountain St
Belfast, BT1 5EB, United Kingdom

Smarkets
Smarkets (Malta) Limited
The Hedge Business Center, Level 7, Triq Ir-Rampa ta’ San Giljan
St. Julians, STJ1062, Malta

Sorare
Sorare SAS
5, Avenue du General de Gaulle
a Saint Mande, 94160, France

sportbet.com
5Dimes Casino and Sportsbook dba sportbet.com
Edificio Equus
San Jose, Costa Rica

Sports Interaction
Mohawk Online dba Sports Interaction
2006 Old Malone Rd, PO Box 1539
Kahnawake, QC, J0L 1B0, Canada

Sportsbetting.ag
Blue High House S.A. dba Sportsbetting.ag
Area Bancaria, Avenida Balboa
Panama City, Panama

Sportsbook
Paddy Power Betfair dba sportsbook.eu
Belfield Office Park, Beech Hill Rd
Clonskeagh, Dublin, 4, Ireland

swcpoker
OrangeWebsite.com dba swcpoker (aka Seals With Clubs, swcpoker.eu)
Kapparstigur 7
Reykjavik, Iceland

The Greek
WS Processing Ltd. dba The Greek Sportsbook
#1 Mangrove Way, M.B.F.Z.
Freeport, Montego Bay, Jamaica

Tiger Gaming
Troy Logic Limited dba Tiger Gaming
170, Patar House, Level 1 (Ste A203), Psaila St
Birkirkara, BKR9077, Malta

Titan Poker
Universe Entertainment Services Malta Limited dba Titan Poker
Level 3, Valletta Bldgs, South St
Valletta, VLT1103, Malta

TopBet.eu
TopBet.eu
support@topbet.eu
Manila, Philippines

TransferWise
TransferWise
6th Flr, The Tea Bldg, 56 Shoreditch High St
London, E1 6JJ, United Kingdom

TryLNK.com
TryLNK.com
csd@trylnk.com
Amsterdam, Netherlands

True Poker
BMX Entertainment S.A. dba True Poker
Sabana Sur, Edificio La Colmena Contigo a Grupo Sama
San Jose, Costa Rica

Unibet
Trannel International Ltd. dba Unibet
Level 6, The Centre, Tigne, Point
Sliema, Malta

Vauld
Defi Payments Pte Ltd dba Vauld
80 Raffles Pl, #32-01 UOB Plaza
Singapore, 048624, Singapore

Vietbet
5Dimes Casino and Sportsbook dba Eurobet
Edificio Equus, San Pedro de Montes de Oca, 7mo Piso
San Jose, Costa Rica

WagerWeb
WagerWeb.ag
support@wagerweb.ag
San Jose, Costa Rica

William Hill
WHG (International) Ltd
6/1 Waterport Place
Gibraltar, Gibraltar

Winamax.fr
Winamax
CS 50746, CEDEX 07
Paris, 75345, France

Winner Poker
Universe Entertainment Service Malta dba Winner Poker
Level 3, Valletta Bldgs, South St
Valletta, VLT 1103, Malta

WPTPoker.com
Electraworks Limited (bwin.party digital entertainment plc) dba WPTPoker
Ste 711, Europort
Gibraltar, Gibraltar

Yobit
Yobit.net
support@yobit.net
Moscow, Russia

Youwager.eu
Dowson Universal Technologies Limited dba Youwager.eu
20 Stuart Ct
Consett, County Durham, DH8 5GA, United Kingdom (hide)

If anyone has additions or corrections to the list feel free to email them to me.

On Exchanging Cryptocurrency for Casino Chips (or Cash)

Monday, August 22nd, 2022

The high stakes poker world works a little differently than you might think.  Most of the players frequenting these games know each other, and borrowing money from one another is common.  Another common occurrence is the exchanging of cryptocurrency for casino chips.  Let’s look at an example.

Russ, a professional poker player, is playing high stakes, and he’s not having a good day.  He needs another $100,000 to stay in the game.  He asks Alice (another professional poker player), can I send you $100,000 of Bitcoin for $100,000 of casino chips?  (Alice knows that Russ will send her the cryptocurrency.)  Russ logs into his online wallet, transfers the Bitcoin to Alice’s address (her Bitcoin wallet), and Alice hands Russ $100,000 of casino chips.  All is well, right?

Not exactly.  Sure, Alice received $100,000 worth of Bitcoin for $100,000 of casino chips but she now might be guilty of money laundering.  At minimum, a currency transaction report (CTR) might be required.

The anti-money laundering laws are complex, and I’m not an attorney.  But the basic idea is that exchanging one kind of cash-valued item for something considered to be cash requires knowing your customer and following the rules and regulations set by FINCEN (the Financial Crimes Enforcement Network) under the Bank Secrecy Act and the Patriot Act (and there are others, including state laws).  If you regularly take in cash (or a cash equivalent) and are exchanging it for something else (or vice versa), you may fall under the definition of non-bank financial institution.  And a single transaction (like the one above) may make someone guilty of money laundering.

So let’s say you’re playing high stakes poker, and someone wants to exchange some Bitcoin for casino chips.  Should you do this exchange (knowing you will get the cryptocurrency)?  My advice is that because of the anti-money laundering laws you should not.

When Bad Recordkeeping Helps You (And Bad News for Some Canadian Professional Poker Players)

Monday, July 18th, 2022

As we previously reported, the Canada Revenue Agency (CRA) thought that Jonathan Duhamel, the winner of the Main Event of the World Series of Poker (WSOP) in 2010 was a professional gambler, and that he conducted himself as a professional gambler.  Thus, his gambling winnings should be subject to Canadian income tax.  Mr. Duhamel argued that poker is a game of chance and not subject to tax in Canada, and that even if it were a game of skill Mr. Duhamel did not conduct himself as a professional poker player.  The case was tried in front of the Tax Court of Canada last November, and a decision was released late last month.  (I am indebted to a friend of mine who speaks French for translating the key points of the decision — his translation runs 40 pages.)

The evidence as presented to the court showed that Mr. Duhamel was bad at recordkeeping.  He apparently only kept track of his tournament results, and never tracked cash games (even though he played lots of cash games).  For a Canadian who doesn’t want to be considered a professional gambler, bad recordkeeping appears to be a plus as this was a factor that influenced the court.

(Of course, if you are an American—and this blog caters to Americans—a warning is needed.  Bad recordkeeping is not what you want to do as either an amateur or a professional gambler in the United States.  All gamblers in the United States must pay tax on their winnings, and a gambling log is a must.  But I digress….)

The Court noted (as translated) [1]:

Because the evidence shows that chance is a very important element in poker game results, that Mr. Duhamel’s poker game activities do not demonstrate an ability to generate profits, that the probability Mr. Duhamel’s ruin in his poker gambling business is well over 50% (but less than 87%), that Mr. Duhamel does not act like a serious businessman in his poker gaming activities, that Mr. Duhamel has not developed any system for managing or mitigating risks in connection with his poker gaming activities and that the financial results of his tournaments do not show any consistency or progress in the results, the Court concludes, on a balance of probabilities, that Mr. Duhamel’s poker gaming activities are not carried on in a sufficiently commercial manner to constitute a source of business income for the purposes of the Act. Accordingly, the net earnings from Mr. Duhamel’s poker gaming activities should not be included in the calculation of his income under sections 3 and 9 for the 2010, 2011 and 2012 taxation years.

The court looked at the activities of Mr. Duhamel, and found that he acted as an amateur; for Mr. Duhamel, this decision is excellent news.  Mr. Duhamel won in part because he didn’t act like he was in business.

However, there is bad news implicit in this decision for some Canadian professional poker players:  It’s clear that there are Canadian poker players who consistently make their living from poker, and who would likely be considered professional gamblers if the CRA were to look at their activities.  I don’t practice in Canada, but I would advise any Canadian professional poker player to seek advice from a Canadian tax professional who understands gambling activities and this decision.

 

[1] This paragraph in French reads, “Puisqu’il ressort de la preuve que le hasard est un élément très important dans les résultats au jeu de poker, que les activités de jeu de poker de M. Duhamel ne démontrent pas une capacité de générer des profits, que la probabilité de ruine de M. Duhamel dans le cadre de ses activités de jeu de poker est bien supérieure à 50 % (mais inférieure à 87 %), que M. Duhamel n’agit pas comme un homme d’affaires sérieux dans le cadre de ses activités de jeu de poker, que M. Duhamel n’a mis au point aucun système de gestion ou d’atténuation des risques dans le cadre de ses activités de jeu de poker et que les résultats financiers de ses tournois ne démontrent aucune constance ni progression dans les résultats, la Cour conclut, selon la prépondérance des probabilités, que les activités de jeu de poker de M. Duhamel ne sont pas exercées de manière suffisamment commerciale pour constituer une source de revenu d’entreprise aux fins de la Loi. Conséquemment, les gains nets tirés des activités de jeu de poker de M. Duhamel ne doivent pas être inclus dans le calcul de son revenu aux termes des articles 3 et 9 pour les années d’imposition 2010, 2011 et 2012.”