A Reminder for Charities and Officers in Charities

February 15th, 2024

I live in a swing district in a swing state.  One of the things we dread is election mail.  The primary for state offices is in June, and already we’re receiving flyers.  I’m sure the robocalls are soon to come (the robo-texts have already begun). The television and radio ads have begun (there was an advertisement during the Super Bowl for a candidate). November 6th can’t come soon enough.

I happened to need to link to a blog post I wrote four years ago, and I noticed the previous post dealt with charities and the election.  Charities are defined in Section 501(c)(3) of the Tax Code.  It’s seems quite timely to remind everyone that one of the things charities cannot do is endorse a candidate.

So what does this cover? It includes the obvious (making political contributions, endorsing candidates, or speaking in favor or against a candidate) and some less obvious items (leasing space to a political campaign and using the organization’s mailing or email list for a campaign). There’s no de minimis rule, so if your 501(c)(3) gives $1 to the Trump or Biden campaigns, you could lose your 501(c)(3) status.

There’s a corollary that I want to emphasize: Officers (and employees) of 501(c)(3) charitable organizations must be very careful about their public statements for (or against) any candidate or cause. I am officer of and on the Board of Directors of a 501(c)(3) charity.  Let’s say I am for Assemblyman Smith in her candidacy for Nevada State Senate. I publicly endorse her. Of course, I, as an individual, can endorse whomever I wish. But I’m also an officer of a 501(c)(3). In my endorsement, did I note that this was my endorsement, and that nothing I’m saying is attributable to that charity? Am I careful doing that in all social media?

From a practical sense, it’s unlikely the IRS would go after a charity or a public foundation (which are 501(c)(3) charities). But they can, and an ounce of prevention is worth a pound of cure. If you’re an officer of a 501(c)(3) organization, it’s an excellent idea to make sure all officers and employees are aware of the rules.

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Posted in IRS | Comments Closed

Do I Really Have to Wait for that $10 K-1 to Arrive?

February 12th, 2024

Earlier this week, a client came in for his annual visit (call him John).  John invested in a new investment partnership this year, and he was told by the partnership that the only item on his K-1 will be exactly $10 of interest income.  But John does not have the K-1; indeed, he won’t have it until sometime in July.  Does John have to wait until July to file his tax return?

Yes, he does.

The statement can be used to determine how much tax John owes for 2023; however, it cannot be used for filing.  You must have all your tax documents including all K-1s before you file.  It is far, far better to extend than amend.  Yes, that K-1 (for John) results in $3 or so of tax and is close to irrelevant for his tax situation.  But who knows what other items are on it?

When the K-1 is actually issued there could be:

  • A change from the $10 in interest income to something else;
  • Perhaps some of the interest income isn’t taxable on either the federal or state level; and
  • Perhaps there are other items that will be on the K-1 that have to be entered.

The K-1 is determinative in preparing (and filing) a tax return; the statement is not.  I know this personally: I’m an investor in a partnership whose K-1 shows up every year in early August.  In late March I’ll get a statement (similar to the one John has) noting their projected items of income and deductions so I can file an extension (and make an extension payment).  In the case of the partnership I invested in, they’ve invested in other entities and have to wait for the results of those underlying investments to formally arrive before issuing the K-1s.

When you invest in a partnership or S-Corporation, you need to be aware that to file by the April deadline you will have to have that K-1.  Partnerships and S-Corporations can (and these days often) obtain extensions until September 15th.  If you invest in an entity that takes the extra six months, you will be extending your tax return. 

John knew coming in that he would be extending.  He spoke to me last year about the new investment, and I told him an extension was likely.  If you make such an investment, be aware that an extension is likely in your future.

 

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Online Gambling and Cryptocurrency Addresses for 2024

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

4Casters
Vortex Venture Group Limitada dba 4Casters
vortexventuregroup@proton.me
Podgorica, Montenegro

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

BingX
BingX SG PTE Ltd
10 Anson Rd
Singapore, Singapore

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

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

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

ByBit
ByBit
One Central, Dubai World Trade Center
Dubai, United Arab Emirates

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

Casinozer.com
Altacore N.V. dba Casinozer.com
Dr. Henri Fergusonweg 1
Gaito, Curacao (Netherlands Antilles)

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

Crown Casino
TechSolutions Group N.V. dba Crown Casino
50 Abraham Mendez Chumaceiro Blvd
Willemstad, Curacao (Netherlands Antil

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

Phemex
Phemex
1 Irving Pl, #08-11; The Commerze-Irving
Singapore, 369546, Singapore

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

Thunderpick.io
Paloma Media B.V. dba Thunderpick.io
Kaya Richard J. Beaujon Z/N
Willemstad, Curacao (Netherlands Antilles)

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

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

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.

Posted in Cryptocurrencies, FINCEN, Gambling | Comments Closed

A Retroactive Tax Bill: What Can Go Wrong?

February 1st, 2024

Last night, the House of Representatives passed tax legislation that would increase the Child Tax Credit for 2023, allow businesses to expense research and development expenses, tax relief for wildfires and the train derailment in East Palestine, Ohio, and some other provisions.  This legislation is now in the hands of the Senate, and it’s possible it won’t go anywhere (or it could pass tomorrow).  Issues that could derail the bill in the Senate include the SALT cap (the limit of $10,000 deduction on federal tax returns for state taxes paid), election year politics, and the fact that little has come out of the Senate.  And if it gets amended in the Senate, back to the House it goes.

Let’s assume it passes; that would require the IRS to reprogram its computers.  The IRS uses the best of 1959 technology, so this would take a month or so.  Do we file tax returns for individuals (and businesses) impacted by this?  If this passes, impacted individuals (and businesses) who file now might need to amend their returns.  The IRS isn’t expedient in processing amended returns, so that’s not a great option.

Unfortunately, there is no best option.  Each impacted taxpayer is going to have to decide whether or not to file now or extend.  If we get an indication from the Senate whether this bill will pass or not, we may be able to make better decisions. Even though I reside in the capital of gambling and odds, I can’t provide you a quote of the chance this bill passes as written and gets signed into law.

I was hoping for a nice, simple straightforward Tax Season.  Unfortunately, Congress had different ideas.

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Posted in IRS, Legislation | Comments Closed

IRS Announces Simple Notice Initiative; Boy, Is It Needed

January 24th, 2024

Clients of ours received an IRS CP2000 alleging they owed additional tax.  The clients called us, and we reviewed their return; it turns out that the items the IRS thought weren’t included on their return were included (so we believe no tax is owed). We sent a response in early December.

Last week our clients received a response (we were supposed to have been copied, but we weren’t):

Our clients were perplexed by the response. Frankly, the following paragraph would perplex anyone:

Before we can resolve this matter, we need information from , and we haven’t received it yet. You should receive our complete response within   days. We don’t need any further information from you right now.

Most likely, this paragraph wasn’t supposed to be included (and only the previous paragraph noting that we’d receive another response within 90 days should have been included).  If you think this is a one-off, it’s not; a second client (who responded to an IRS notice on her own) received the identical response.

About an hour after the phone call I received an email from the IRS noting, “IRS launches Simple Notice Initiative resdesign effort.”  That’s needed, along with someone proofreading notices and responses before sending them.  The IRS is promising to redesign “up to 200 notices that make up about 90% of total notice volume sent to individual taxpayers.”  We shall see.

Posted in IRS | Comments Closed

IRS Officially Announces Delay in Reporting Cryptocurrency Transactions on Form 8300

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.

Posted in Cryptocurrencies, FINCEN, Gambling, Information Returns, IRS | Comments Closed

Form 8300 and Cryptocurrency: Implementation Postponed

January 12th, 2024

The IRS sent emails to two tax professionals regarding Form 8300 and cryptocurrency:

Treasury has postponed the effective day of 12/31/2023 for filing 8300 forms regarding digital asset transactions (Cryptocurrency). The updated [form] as well as guidance on electronic filing the 8300 form will be on the IRS.gov website soon.

Both FinCEN and the IRS are within the Department of the Treasury.  I’ll post a further update when it’s available.

Posted in Cryptocurrencies, FINCEN | Comments Closed

Form 8300, Cryptocurrency, and Gambling: An Update

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.

 

Posted in FINCEN, Gambling, Information Returns, IRS | Comments Closed

It’s Time to Start Your 2024 Mileage Log

January 3rd, 2024

I’m going to start the new year with a couple reposts of essential information. Yes, you do need to keep a mileage log:

Yesterday was the first business day of the new year for most. You may have resolved to keep good records this year (at least, we hope you have). Start with keeping an accurate, contemporaneous written mileage log (or use a smart phone app–with periodic sending of the information to yourself to prove that the log is contemporaneous).

Why, you ask? Because if you want to deduct all of your business mileage, you must do this! IRS regulations and Tax Court rulings require this. Written is defined as ink, so that means you need a paper log or must be able to prove your smart phone log is contemporaneous.

The first step is to go out to your car, and note the starting mileage for the new year. So go out to your car, and jot down that number (mine was 133,599). That should be the first entry in your mileage log. I use a small memo book for my mileage log; it conveniently fits in the center console of my car. It’s also a good idea to take a picture of the odometer and email that picture to yourself. This will give you a time-stamp showing you accurately noted your beginning mileage.

Here’s the other things you should do:

On the cover of your log, write “2024 Mileage Log for [Your Name].”

Each time you drive for business, note the date, the starting and ending mileage, where you went, and the business purpose. Let’s say you drive to meet a new client, and meet him at his business. The entry might look like:

1/4 133900-133935 Office-Acme Products (1234 Main St, Las Vegas)-Office, Discuss requirements for preparing tax return, year-end journal entries.

It takes just a few seconds to do this after each trip, and with the standard mileage rate being $0.66/mile, the 35 miles in this hypothetical trip would be worth a deduction of $23. That deduction does add up.

Some gotchas and questions:
1. Why not use a smartphone app? Actually, you can but the current regulations require you to also keep a written mileage log. You can transfer your computer app nightly to paper, and that way you can have the best of both worlds. Unfortunately, current regulations do not guarantee that a phone app will be accepted by the IRS in an audit.

That said, if you backup (or transfer) your phone app on a regular basis, and can then print out those backups, that should work. The regular backups should have identical historical information; the information can then be printed and will function as a written mileage log. I do need to point out that the Tax Court has not specifically looked at mileage logs maintained on a phone. A written mileage log (pen and paper) will be accepted; a phone app with backups should be accepted.

2. I have a second car that I use just for my business. I don’t need a mileage log. Wrong. First, IRS regulations require documentation for your business miles; an auditor will not accept that 100% of the mileage is for business–you must prove it. Second, there will always be non-business miles. When you drive your car in for service, that’s not business miles; when you fill it up with gasoline, that’s not necessarily business miles. I’ve represented taxpayers in examinations without a written mileage log; trust me, it goes far, far easier when you have one.

3. Why do I need to record the starting miles for the year? There are two reasons. First, the IRS requires you to note the total miles driven for the year. The easiest way is to note the mileage at the beginning of the year. Second, if you want to deduct your mileage using actual expenses (rather than the standard mileage deduction), the calculation involves taking a ratio of business miles to actual miles.

4. Can I use actual expenses? Yes. You would need to record all of your expenses for your car: gas, oil, maintenance, repairs, insurance, registration, lease fees (or interest and depreciation), etc., and the deduction is figured by taking the sum of your expenses and multiplying by the percentage use of your car for business (business mileage to total mileage driven). Note that once you start using actual expenses for your car, you generally must continue with actual expenses for the life of the car. Be careful if you (or your family) have multiple vehicles. You will need to separate out your expenses by vehicle.

So start that mileage log today. And yes, your trip to the office supply store to buy a small memo pad is business miles that can be deducted.

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Posted in IRS | Comments Closed

The 2023 Tax Offender of the Year

December 29th, 2023

So many try every year for my award–The Tax Offender of the Year.  It’s not really something to be proud of; after all, to win this award you need to commit really big tax fraud or a series of Bozo-like actions (ideally, both).  As usual, there are plenty of candidates but there can only be one “winner.”

Just missing out of the top three were Ali Jaafar and Yousef Jaafar of Watertown, Massachusetts.  They came up with the not-so-brilliant idea of unlawfully claiming 14,000 winning Massachusetts lottery tickets, laundering the $20 million in proceeds, and lying on their tax returns.  They each get to spend five years at ClubFed and make restitution of $6,082,578 and must forfeit their profits on the scheme.

Also just missing the top three was Las Vegas resident Scott Lawrence.  Mr. Lawrence operated a real estate business that did quite well from 2009 through 2019; he just didn’t want to pay the $1,905,325 in taxes he owed.  He elected to deliberately thwart efforts to levy his bank account and caused his attorney to send a misleading letter to the IRS; he then deliberately paid his taxes using an overdrawn bank account.  He’ll enjoy a year and a day at ClubFed and must make restitution.

Coming in third place was Stephen Schechter, a resident of Monaco.  Mr. Schechter is an investment advisor and is doing quite well.  Back in 2011 he sold an apartment in Monaco for about €14,000,000.  Now, that wasn’t all profit–but quite a bit was.  Unfortunately, that sale didn’t make it onto his 2011 tax return.  Nor were various foreign financial accounts where the money went noted on his FBAR (FinCEN Form 114, the Report of Foreign Bank and Financial Accounts).  Somehow, the interest and dividends from those accounts also didn’t make it onto his returns.  Mr. Schechter pleaded guilty to concealing over $5,130,000 in income from the IRS.

Walter “Terry” Douglas Roberts II, of Flat Rock, North Carolina just missed out on the brass ring.  Mr. Roberts is an appraiser, and he did lots of appraising of conservation easements.  The IRS looks at Syndicated Conservation Easements as part of their “Dirty Dozen” tax scams. Now, not all conservation easements (or syndicated conservation easements) are scams; many are legitimate.  However, when you admit to fraudulently inflating the values of the easements by “…not following normal appraisal methods, making false statements and either personally manipulating or relying on knowingly manipulated data to reach a targeted appraisal value – communicated to him by co-conspirators…,” you’re looking at a problem.  And when those 18 appraisals end up having fraudulent tax deductions totaling $466,961,000 and a tax loss of $129 million, you’re talking big tax fraud.  He has to make restitution of that $129 million plus spend 12 months at ClubFed.

Back in 2004, Congress passed the “American Jobs Creation Act of 2004.” Included within this law was a biodiesel tax credit.  It was extended through various other legislation and allows a tax credit for the production of various biodiesel fuel.  The tax credit $1.00 per gallon of biodiesel and renewable diesel fuel.

Various businesses began throughout the United States to take advantage of this credit and produce environmentally “good” diesel fuel.  One such company was Washakie Renewable Energy, founded by Jacob Kingston.  As noted on their website,

Committed to producing fuel that is sustainable, clean-burning, and domestically accessible, Washakie Renewable Energy (WRE) is the most significant producer of biofuel in the Intermountain West region. By operating the largest seed crush press in the US, and relying on recycled waste materials like used kitchen grease and cooking oil, Washakie Renewable Energy produces over ten million gallons of biodiesel annually.

The biodiesel produced by WRE is the only alternative fuel to complete the EPA’s study under the Clean Air Act regarding emissions and health effects. In comparison to conventional diesel, biodiesel produces only 14% of the greenhouse gases, 33% of the hydrocarbon emissions, and 53% of the particulate matter, while also being quickly biodegradable and less toxic than common table salt.

Washakie Renewable Energy’s commitment to conscientious resource management includes distributing several useful byproducts of its biodiesel operation, including high-quality animal feed and refined glycerin.

That seems great, doesn’t it? A business making money, giving back to the community, and helping the environment.  What could be wrong with that? Let’s just say that you can only sell 100% of something and follow along with what happened.

The conspiracy began in 2010 and continued through 2018 and involved multiple fraudulent schemes. One involved purchasing biodiesel from the East Coast of the United States (which had been produced by others who had already claimed the renewable fuel tax credit) and exporting it to foreign countries, including Panama, then doctoring transport documents to disguise and import the biodiesel as “feedstock.” Washakie used this false paperwork to claim it had produced biodiesel from the feedstock to support its filing of fraudulent claims for IRS biofuel tax credits. Washakie also fraudulently obtained millions of EPA renewable identification numbers that were then sold for approximately $65 million. Later, Dermen and the Kingstons conspired to purchase millions of gallons of biodiesel and rotate it though the U.S. shipping system to create the appearance that qualifying fuel was being produced and sold by Washakie. Washakie applied for and was paid by the IRS over $300 million for its claimed 2013 production and over $164 million for its claimed 2014 production. Evidence at Dermen’s trial showed that, to further create the appearance of legitimate business transactions, Dermen and the Kingstons schemed to cycle their and other co-conspirators’ fraud proceeds in more than $3 billion in financial transactions through multiple bank accounts.

I can’t say it was all a scam; however, it appears to have mostly been a scam.  Lots of the biodiesel they produced had already been produced and the biodiesel tax credit already taken.  So Washakie had low production costs (after all, they didn’t really produce it), a high profit margin, and lots and lots of refundable renewable fuel tax credits.  Indeed, the individuals involved: Lev Dermen, Jacob Kingston, Isaiah Kingston, Rachel Kingston, and Sally Kingston caused over $1 billion in fraudulent tax credits with $511 million paid to Washakie.

Where did that money end up?  A 150-foot yacht named the Queen Anne (seized in Lebanon and sold for over $10 million in Cyprus), $700,000 of land in Belize that was going to go for a casino, a 2010 Bugatti Veyron (worth $1.8 million), a Lamborghini and Ferrari, and a $3.5 million mansion; investments in other businesses; and, of course, millions sent to friends and family.

The individuals involved attempted to hide their actions by moving money to various countries outside the United States (primarily Turkey and Luxembourg).  Mr. Dermen also made an assurance to Jacob Kingston: “…Dermen falsely assured Jacob Kingston that Kingston and his family would be protected by Dermen’s “umbrella” of corrupt law enforcement and immune from criminal prosecution.” Oops.

Lev Derman (the president of Washakie) was found guilty back in 2020 of conspiracy to commit mail fraud, conspiracy to commit money laundering, and money laundering.  Jacob Kingston pleaded guilty in 2019 to various fraud and tax charges.  Isaiah Kingston and the other members of the Kingston family likewise pleaded guilty in 2019.

Mr. Dermen, who is 56, was sentenced to 40 years (essentially a life sentence), Jacob Kingston received 18 years with other members of the Kingston family receiving between six and 12 years at ClubFed.  Dermen was also ordered to make restitution of $442.6 million and to pay a money judgement of $181 million.  Jacob and Isaiah Kingston were each ordered to pay $511 million in restitution to the IRS. Meanwhile, the Department of Justice is continuing efforts to seize various assets to satisfy the $511 million in restitution.

A helpful hint to all: The Producers is a great play (and movie), but (a) don’t try to sell more than 100% of something and (b) conspicuous consumption while committing fraud usually doesn’t end well.  Lev Derman and the Kingston Family are worthy winners of the 2023 Tax Offender of the Year award.

That’s a wrap on 2023.  I wish all of you and your families a happy, healthy, prosperous and safe New Year!

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Posted in International, IRS, Tax Fraud | Comments Closed

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