I like that idea Les, thanks for the info, but I see conflicted information online regarding the ctr. Like this post from wizardofodds website which is confusing me. What they say sounds like what bling said.
From wizardofodds Q and A
"Las Vegas casinos, namely Caesars and Bellagio, have recently been giving me a harder time when cashing out over a few thousand dollars in chips. This past trip when I cashed out $8,000 at Caesers they asked for my Social Security number. When I naturally asked why, they said they couldn’t tell me exactly and all they could do was give me a card mentioning something vague about Title 31. Could you explain to me and your audience in greater detail what exactly is title 31 and, specifically, what will and will not get your flagged by the IRS. Thanks!
James from Los Angeles, CA
Title 31 is a regulation stating that the casino should make a record of cash transactions of over $10,000 by a single player in a single day. In such cases, a CTR must be filled out, which stands for Cash Transaction Report. This includes making multiple transactions, adding up to over $10,000. If you cash chips close to, but under, $10,000, the cage will likely want to make a note of it, in case you come back later that day, and go over the $10,000 daily limit.
My advice is to give them what they ask for. You have a lot more to fear by looking like you are avoiding CTRs than the CTRs themselves. In fact, I think there is nothing to fear from a legitimate CTR; the casinos generate lots of them. Personally, I have generated hundreds, to no known detriment. However, it raises lots of attention when you look like you are going out of your way to avoid them. I know one person who was rebuffed when he tried to cash in chips, because he had too many previous redemptions of just under $10,000. So, that is my two cents. Better suited to answer this is "Brian," a current Las Vegas casino manager, and former regulator, whom I like to turn to for procedural questions like this.
In a nutshell, Title 31 is the U.S. Department of Treasury Code designed to prevent money laundering. It requires that certain large cash transactions be reported to the Government. These are filed on FinCEN Form 103 “Currency Transaction Reports by Casinos” (FinCEN is the Financial Crimes Enforcement Network). Casinos are required to report all currency transactions in excess of $10K in a single day. The “day” doesn't follow the clock - a casino picks their day (e.g., 3 a.m. to 2:59 a.m.).
All Financial Institutions comply with Title 31. Casinos are considered financial institutions because of the types of transactions they perform, which are similar to those of a bank (e.g., check cashing, wires, loans, cash exchanges). Unlike traditional financial institutions, casinos conduct a great deal of transactions with unknown patrons. When you set up your checking account at the bank, you give them all of the necessary information needed to fill out CTRs. However, when cashing chips at the cage, the only way the casino can get this information is to ask. Casinos have to get all of the necessary information to fill out a CTR before the patron crosses the $10,000 threshold. Since the fines for non-compliance are hefty, they make a diligent effort to comply.
Casinos are apprehensive to give patrons too much information on Title 31 for fear of inadvertently breaking the law. Casinos are specifically precluded from aiding patrons in structuring transactions in such a manner as to allow them to skirt the requirements. When you ask questions, they prefer to point to a preprinted informational card and don’t like to discuss the matter for fear of divulging inappropriate information.
Circumventing Title 31 is relatively easy for undocumented transactions (e.g., chip buys, chip redemptions, etc.), but why would you want to? If the casino has reason to believe that you are purposefully conducting your transactions in an effort to avoid the reporting requirements of Title 31, they'll fill out a Suspicious Activity Report by Casinos form (aka SARC). If a casino learns that you exceeded the $10K threshold and they didn't get the required information, they will bar you from gaming until they get it. — Brian
Bling- you're saying basically if lucky enough to win the bet bite the bullet and pay the tax because the casino will have record and if they know then the IRS could potentially know from title 31 thing?
Les - I didn't have that much reported income last year so if I try this and get C-tracked a few times during the visit it would potential look suspicious that a guy who didn't make that much keeps cashing out 7 or 8 grand multiple times, then reported no gambling winnings on tax forms.
Bling- you're saying basically if lucky enough to win the bet bite the bullet and pay the tax because the casino will have record and if they know then the IRS could potentially know from title 31 thing?
Les - I didn't have that much reported income last year so if I try this and get C-tracked a few times during the visit it would potential look suspicious that a guy who didn't make that much keeps cashing out 7 or 8 grand multiple times, then reported no gambling winnings on tax forms.
Would the casino take the tax out then? Or would I have to do it later?
Would the casino take the tax out then? Or would I have to do it later?
I like that idea Les, thanks for the info, but I see conflicted information online regarding the ctr. Like this post from wizardofodds website which is confusing me. What they say sounds like what bling said.
From wizardofodds Q and A
"Las Vegas casinos, namely Caesars and Bellagio, have recently been giving me a harder time when cashing out over a few thousand dollars in chips. This past trip when I cashed out $8,000 at Caesers they asked for my Social Security number. When I naturally asked why, they said they couldn’t tell me exactly and all they could do was give me a card mentioning something vague about Title 31. Could you explain to me and your audience in greater detail what exactly is title 31 and, specifically, what will and will not get your flagged by the IRS. Thanks!
James from Los Angeles, CA
Title 31 is a regulation stating that the casino should make a record of cash transactions of over $10,000 by a single player in a single day. In such cases, a CTR must be filled out, which stands for Cash Transaction Report. This includes making multiple transactions, adding up to over $10,000. If you cash chips close to, but under, $10,000, the cage will likely want to make a note of it, in case you come back later that day, and go over the $10,000 daily limit.
My advice is to give them what they ask for. You have a lot more to fear by looking like you are avoiding CTRs than the CTRs themselves. In fact, I think there is nothing to fear from a legitimate CTR; the casinos generate lots of them. Personally, I have generated hundreds, to no known detriment. However, it raises lots of attention when you look like you are going out of your way to avoid them. I know one person who was rebuffed when he tried to cash in chips, because he had too many previous redemptions of just under $10,000. So, that is my two cents. Better suited to answer this is "Brian," a current Las Vegas casino manager, and former regulator, whom I like to turn to for procedural questions like this.
In a nutshell, Title 31 is the U.S. Department of Treasury Code designed to prevent money laundering. It requires that certain large cash transactions be reported to the Government. These are filed on FinCEN Form 103 “Currency Transaction Reports by Casinos” (FinCEN is the Financial Crimes Enforcement Network). Casinos are required to report all currency transactions in excess of $10K in a single day. The “day” doesn't follow the clock - a casino picks their day (e.g., 3 a.m. to 2:59 a.m.).
All Financial Institutions comply with Title 31. Casinos are considered financial institutions because of the types of transactions they perform, which are similar to those of a bank (e.g., check cashing, wires, loans, cash exchanges). Unlike traditional financial institutions, casinos conduct a great deal of transactions with unknown patrons. When you set up your checking account at the bank, you give them all of the necessary information needed to fill out CTRs. However, when cashing chips at the cage, the only way the casino can get this information is to ask. Casinos have to get all of the necessary information to fill out a CTR before the patron crosses the $10,000 threshold. Since the fines for non-compliance are hefty, they make a diligent effort to comply.
Casinos are apprehensive to give patrons too much information on Title 31 for fear of inadvertently breaking the law. Casinos are specifically precluded from aiding patrons in structuring transactions in such a manner as to allow them to skirt the requirements. When you ask questions, they prefer to point to a preprinted informational card and don’t like to discuss the matter for fear of divulging inappropriate information.
Circumventing Title 31 is relatively easy for undocumented transactions (e.g., chip buys, chip redemptions, etc.), but why would you want to? If the casino has reason to believe that you are purposefully conducting your transactions in an effort to avoid the reporting requirements of Title 31, they'll fill out a Suspicious Activity Report by Casinos form (aka SARC). If a casino learns that you exceeded the $10K threshold and they didn't get the required information, they will bar you from gaming until they get it. — Brian
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