Cash vs checks, CTRs, taxes, and dealing with cash in general

I'm curious what this forum thinks about the cash issue. I know about CTRs and STRs, and I know about the legalities surrounding structuring. The general goal I have is to transfer cash I win in a casino into my bank account while minimizing suspicion (both casino and government) and tax liability. Nevermind the "why" (ie, why would you deposit it in the bank if you will gamble again and need access to cash...), let's just consider the how.

I am also aware that taxing on table games, where the payout is less than 300:1 or whatever, is on the honor system. That means, you are required to declare net winnings (losses up to winning total can be deducted) on your tax form at the end of every fiscal year. In fact, even if you net lose over a whole year but have had winning "sessions", you still have to declare those wins but you deduct their full amount resulting in zero liability. But, quite seriously, most people don't go through any of this, and up to a certain point, it probably isn't worth the trouble for the IRS to follow up on suspected "evasion" from gambling winnings.

Specific issues/questions:
- Cash transactions exceeding $10k over 24h generate a currency transaction report, which requires you to disclose your name and SSN at the cage (this is whether you withdraw or deposit >$10k in cash). How do these get treated by the government agency which receives them? Specifically, does the IRS know you gamble (and will they expect your tax return to reflect some gambling) as a result of the CTR trigger?

- Depositing cash into a bank account raises flags if you do so regularly and it doesn't fit your profile. Do / should you disclose that you are a gambler or that you won money in a casino? Does that information make its way to the IRS, increasing (again) the likelihood of them expecting a gambling portion in your tax return? Or should you wait until you amassed a certain amount and file a CTR when depositing at the bank (versus doing so at the casino)?

- At what point do people here consider the tax liability issue to be serious enough to actually self-declare any casino winnings?

- At what point (how much $$) would you request a check from a cage rather than cash?

Quote: arcticfun

I'm curious what this forum thinks about the cash issue. I know about CTRs and STRs, and I know about the legalities surrounding structuring. The general goal I have is to transfer cash I win in a casino into my bank account while minimizing suspicion (both casino and government) and tax liability. Nevermind the "why" (ie, why would you deposit it in the bank if you will gamble again and need access to cash...), let's just consider the how.

I am also aware that taxing on table games, where the payout is less than 300:1 or whatever, is on the honor system. That means, you are required to declare net winnings (losses up to winning total can be deducted) on your tax form at the end of every fiscal year. In fact, even if you net lose over a whole year but have had winning "sessions", you still have to declare those wins but you deduct their full amount resulting in zero liability. But, quite seriously, most people don't go through any of this, and up to a certain point, it probably isn't worth the trouble for the IRS to follow up on suspected "evasion" from gambling winnings.

Specific issues/questions:
- Cash transactions exceeding $10k over 24h generate a currency transaction report, which requires you to disclose your name and SSN at the cage (this is whether you withdraw or deposit >$10k in cash). How do these get treated by the government agency which receives them? Specifically, does the IRS know you gamble (and will they expect your tax return to reflect some gambling) as a result of the CTR trigger?

- Depositing cash into a bank account raises flags if you do so regularly and it doesn't fit your profile. Do / should you disclose that you are a gambler or that you won money in a casino? Does that information make its way to the IRS, increasing (again) the likelihood of them expecting a gambling portion in your tax return? Or should you wait until you amassed a certain amount and file a CTR when depositing at the bank (versus doing so at the casino)?

- At what point do people here consider the tax liability issue to be serious enough to actually self-declare any casino winnings?

- At what point (how much $$) would you request a check from a cage rather than cash?

You seem to be using the term "tax liability" incorrectly.

Your tax liability is the amount of money that you owe. It doesn't change, regardless of whether the government knows about the money or not.

You seem to be asking for advice on how get away with cheating on your taxes, as well as how to structure without getting caught. I don't have good advice for either of those things, but I would generally suggest not announcing your intention to commit multiple felonies on a public forum.

The IRS doesn't necessarily know you gamble. They know you have income with a CTR or SAR. So it is at that point that if you are paying no taxes and lying to the IRS, that they may suspect something and audit you.
If you are below the reporting requirements, then it is probably not serious enough to involuntarily pay. Although people can still rat you out, such claims are often not taken seriously because they lack evidence and it would cost more to pursue than you actually owe. Not that it is ever a good idea to evade taxes.
If you are generating CTRs, you must report something or there is a high chance of serious consequences, bottom line.

That is about the best help you are going to get with your question, I believe. I would suggest you "structure" (pun intended) your question in a different way, maybe asking how to avoid CTRs. I don't really care if you shoot up heroine before you kidnap a school bus full of kids to keep in your dungeon; I'm not your accomplice if I tell you that drugs can be found in the streets of any metropolitan area, and that kids can be easily coaxed with candy. But others are going to come on here and hound you about committing felonies.

You should not put a bunch of money in your bank account and then hope that you are never audited. You should conduct your finances in such a way that if audited, you will not be penalized. There are over 10 million CTR's filed on a yearly basis, having one or two doesn't increase your chance of audit greatly if you pay your taxes. If you CTR for an aggregate of a million dollars and file 0 in taxes, you will be getting a letter. If you do get audited, and you have lots of unclaimed income in your bank account, or lots of assets, you are going to be very sorry.

Honestly, just pay your taxes. I would guess the accuracy of the average gambler's return is positively correlated with net winnings, IE nearly all of the guys who make 7 figures are much more honest because of the intense scrutiny they have. I can only think of one group that filed a dishonest return, and they got blasted by the IRS incredibly hard.

The other thing which you may not realize is that the casino can file SAR's on you anytime you win just because they didn't like the manner in which you won. They can SAR you because you didn't tip - all the pit boss has to do is call the cage manager. Legally, they cannot even tell you that they gave you a SAR, and while it is misuse of the form, it is in no way illegal AFAIK. I would guess most AP's have had this done to them at some point or another. All the more reason to pay your taxes.

Quote: tongni

You should not put a bunch of money in your bank account and then hope that you are never audited. You should conduct your finances in such a way that if audited, you will not be penalized. There are over 10 million CTR's filed on a yearly basis, having one or two doesn't increase your chance of audit greatly if you pay your taxes. If you CTR for an aggregate of a million dollars and file 0 in taxes, you will be getting a letter. If you do get audited, and you have lots of unclaimed income in your bank account, or lots of assets, you are going to be very sorry.

Honestly, just pay your taxes. I would guess the accuracy of the average gambler's return is positively correlated with net winnings, IE nearly all of the guys who make 7 figures are much more honest because of the intense scrutiny they have. I can only think of one group that filed a dishonest return, and they got blasted by the IRS incredibly hard.

The other thing which you may not realize is that the casino can file SAR's on you anytime you win just because they didn't like the manner in which you won. They can SAR you because you didn't tip - all the pit boss has to do is call the cage manager. Legally, they cannot even tell you that they gave you a SAR, and while it is misuse of the form, it is in no way illegal AFAIK. I would guess most AP's have had this done to them at some point or another. All the more reason to pay your taxes.

I'm not sure this is true. Winning is not a suspicious activity; I don't even think cheating falls under the law's purview. If a SARC like this were written up, it may be deemed not suspicious on review, and ultimately not filed. Also, if he has a day job, he pays some taxes. A couple spurious SARCs won't raise a flag. He wants to know how to evade taxes. This is just a scary sounding argument that he should due his civic duty. Like I said, no one is going to give good advice on his question...just don't evade too much.

Quote: AxiomOfChoice

You seem to be using the term "tax liability" incorrectly.

You seem to be asking for advice on how get away with cheating on your taxes, as well as how to structure without getting caught.

It's not quite that black and white. My true intention is to understand what sensible practice is before I take the whole gambling thing seriously. ie, I don't want to take money to a bank a single time and tell them I gamble, have a record of it somewhere follow me 3, 5, 10 years down the line, and have the IRS expect me to include a gambling entry on my taxes after I've quit. Honestly, the whole thing was an experiment that turned out to have better-than-expected results (me winning), and I am now toeing the line between just flirting with this hobby and being serious with it. There's no question on how to behave once I get married to it. Pun intended, lolz.

So - thoughts on value amounts? how much money would you have to have in chips before you asked for a check? (safety and mugging issues aside). Does a CTR from a casino trigger more or less interest than a CTR from a bank?

Quote: arcticfun

It's not quite that black and white. My true intention is to understand what sensible practice is before I take the whole gambling thing seriously. ie, I don't want to take money to a bank a single time and tell them I gamble, have a record of it somewhere follow me 3, 5, 10 years down the line, and have the IRS expect me to include a gambling entry on my taxes after I've quit. Honestly, the whole thing was an experiment that turned out to have better-than-expected results (me winning), and I am now toeing the line between just flirting with this hobby and being serious with it. There's no question on how to behave once I get married to it. Pun intended, lolz.

So - thoughts on value amounts? how much money would you have to have in chips before you asked for a check? (safety and mugging issues aside). Does a CTR from a casino trigger more or less interest than a CTR from a bank?

People carry around chips to avoid CTRs, and to avoid buying in for large amounts. It appears as if you are a small player amassing chips to eventually ask for a large check. This makes no sense. You should cash out in full every time, unless these are all excess chips from ratholing. Maybe I am getting the wrong impression.

A CTR is a CTR, does not matter who submits it. It is the number of CTRs that raises concern.

I mean, suppose you have $x in chips from a single weekend, and x > 10k. At what point would you request a check instead of cash? I've walked out of a casino with $15k before, but I cashed chips in over consecutive nights because i was staying at the hotel, so each transaction was less than 10k.

Re: CTRs, isn't there a field on that form that identifies who issues it? and when IRS sees "casino" the deduction is "gambling", whereas if the bank makes it, many other reasons can apply?

Quote: arcticfun

I mean, suppose you have $x in chips from a single weekend, and x > 10k. At what point would you request a check instead of cash? I've walked out of a casino with $15k before, but I cashed chips in over consecutive nights because i was staying at the hotel, so each transaction was less than 10k.

You probably got a CTR. If they didn't file one they aren't doing a very good job.

If you had more than $10k chips in your possession the first night, but cashed < $10k, and cashed the rest the next day, you probably took an unnecessary risk. Even if your intention wasn't to avoid a CTR, it certainly looks like that was your intention.

My advice is this:

Keep records of all your sessions. Wins and losses. When you do your taxes, add up all the wins, and enter that as gambling winnings. Add up all your losses, and enter that as gambling losses. If your wins add up to more than your losses, pay the taxes that you owe.

If you have a big win, you WANT a transaction of it going to your bank. If you have a big loss, you WANT a transaction of it going the other way. That way, if you get audited, and they look at your records (and, they will want to see records), they will see bank transactions that mirror your records. If you have a $25k loss on your record and no bank transactions or CTRs around that time, the auditor will be suspicious. Where did the money for this supposed loss come from? In this case, the CTR helps you.

Just be as honest and transparent as possible. All this cloak and dagger nonsense is likely to cause you more problems than it solves.

Fair enough. Thanks for the thoughts.

Quote: arcticfun

I mean, suppose you have $x in chips from a single weekend, and x > 10k. At what point would you request a check instead of cash? I've walked out of a casino with $15k before, but I cashed chips in over consecutive nights because i was staying at the hotel, so each transaction was less than 10k.

Isn't that structuring?

Quote: RS

Isn't that structuring?

Yes it is.

Quote: geoff

Yes it is.

No, it probably is not as an isolated case. Structuring requires intent to avoid reporting requirements, beyond any reasonable doubt. Since a routine CTR should have been filed and he apparently lacks knowledge on the subject, this suggests he lacked intent. This law has a quirk because ignorance of the law can be a defense.

Quote: geoff

Yes it is.

I think it depends on the circumstances. If I go to a casino for a weekend with $5k in cash, buy in for $2k on Friday, win $6k, and cash out all my $8k, go to sleep, buy in for another $2k on Saturday, win $7k, and cash out all my $9k and go home with $18k in my pocket, that is not structuring. I never had more than $10k in chips in my possession to cash out. The casino will have records showing that I won the money over two days.

On the other hand if I won all $13k on Friday, but cash it out over 2 days, I think it would be difficult to claim that it was not structuring.

Quote: AxiomOfChoice

I think it depends on the circumstances. If I go to a casino for a weekend with $5k in cash, buy in for $2k on Friday, win $6k, and cash out all my $8k, go to sleep, buy in for another $2k on Saturday, win $7k, and cash out all my $9k and go home with $18k in my pocket, that is not structuring. I never had more than $10k in chips in my possession to cash out. The casino will have records showing that I won the money over two days.

On the other hand if I won all $13k on Friday, but cash it out over 2 days, I think it would be difficult to claim that it was not structuring.

If you split the transactions in half, and played equal amounts each day, it probably would not be structuring. If you did not play at all the next day and cashed out $3,001 24 hours after your first cash out, then it probably would be structuring.

Here is where it is important to note the exact differences between CTR's and SAR's. If you are a new player and you do as artic had suggested, cash out over two days, then the casino will generate a SAR and watch you like a hawk. If you repeat the process, then they will get you quick as a flash.

Casinos (and all other financial institutions) take Title 31 VERY seriously. finCEN takes their jobs very seriously too and they are rigorously enforcing the laws. Casinos will attempt to get as much information on your playing habits and indeed your cashing out habits as they deem necessary to make an accurate decision about your intentions.

My suggestion would be very similar to the rest here. Just play with a players card, give the casinos the details they require (ID, Social and the like) and pay your taxes when they are due. Remember, if a casino hands you or sends you a W-2, that means that the IRS has a copy too.

I don't think it is worth messing with your other business or gainful employment just to try and duke the government out of their fair share.

Quote: Sonuvabish

Structuring requires intent to avoid reporting requirements, beyond any reasonable doubt.

I wonder if this applies to casinos as well? Fremont Casino (downtown) has a big advertisement on the side of the building advertising jackpots of $1199! Clearly this is about avoiding that $1200 threshold that requires a hand pay and paperwork. Isn't that the definition of structuring?

Quote: kewlj

I wonder if this applies to casinos as well? Fremont Casino (downtown) has a big advertisement on the side of the building advertising jackpots of $1199! Clearly this is about avoiding that $1200 threshold that requires a hand pay and paperwork. Isn't that the definition of structuring?

No, they are just paying you less than the amount that requires a form. It's not like they are saying, instead of paying you $2000 for your jackpot, we will pay you $1000 on this spin and give you a $1000 bonus on your next spin.

Quote: kewlj

I wonder if this applies to casinos as well? Fremont Casino (downtown) has a big advertisement on the side of the building advertising jackpots of $1199! Clearly this is about avoiding that $1200 threshold that requires a hand pay and paperwork. Isn't that the definition of structuring?

I think the casino is using it as a marketing tool rather than an evation of the threshold. They are attempting to draw customers in who know about the threshold and want to avoid it.

I guess the casinos can offer any jackpot payout they want within the regulations set forth by the NGC.

Same as I have suggested about 3:2 blackjack with liberal rules. Advertise and market that bad boy and hopefully your drop will increase.

The cash-out was over two days because I won on both days and cashed out on both days, not because I was avoiding a single big cash-out. But man, you guys make it sound pretty serious. When I walked to the cage with 7k in chips, the procedure was completely painless and anonymous -- the only thing the cashier asked was if I had any markers (no, I didn't), and had a double count the bills in the 5k stack. In and out in a minute... No player's card required, nothing. Am I completely naive? an SAR for that? .... I didn't feel any heat in that sense whatsoever...

Also, there are no W2s from blackjack.

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Quote: arcticfun

The cash-out was over two days because I won on both days and cashed out on both days, not because I was avoiding a single big cash-out. But man, you guys make it sound pretty serious. When I walked to the cage with 7k in chips, the procedure was completely painless and anonymous -- the only thing the cashier asked was if I had any markers (no, I didn't), and had a double count the bills in the 5k stack. In and out in a minute... No player's card required, nothing. Am I completely naive? an SAR for that? .... I didn't feel any heat in that sense whatsoever...

Also, there are no W2s from blackjack.

It is pretty serious. This is something that you do not want to be accused of.

If they didn't ask for a player's card, they might have already known who you were. If you gave a card at the table, I would not assume that it was anonymous.

Edit: The key here is, don't assume that no CTR or SAR was filed. It may well have been. The fact that it was under $10k does not imply that there was no paperwork.

Quote: arcticfun

Also, there are no W2s from blackjack.

You are right, there is no W-2g from playing blackjack because a payout has to be on a single bet paying out 300-1 or more before a W-2g is printed HOWEVER if you are a winner FOR THE YEAR, no matter what game you play, the casino has to issue you with a W-2g which they mail to your home address (just like your employer) AND they mail to the IRS.

Like Axiom mentioned, don't assume because they didn't ask for your name at the cage that they didn't know how you were. In order to confirm your play the cage would have had to phone the pit who would have given them your name.

Assumptions are not a good place to start.

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Quote: Ibeatyouraces

I don't know one person that has received a w-2g for non jackpot table games play when they've come out ahead art the end of the year.

They play rated AND they come out ahead? Do they only sometimes play rated?

As far as I know the casinos are supposed to send out W-2g's to winning players. Obviously this can only be done through the players club which generates a report at the end of the year once the players are ahead.

Perhaps they have discontinued this practice but as of 2010 it was still being done.

I'll try and get more up to date feedback.

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Quote: Ibeatyouraces

There's no way this can be possible because there is no way that it will be 100% accurate.

I have sent an email to a cage director friend of mine. You could be absolutely right, not going to argue with you.

I will report back when I hear anything.

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Quote: Ibeatyouraces

Possibly a state by state type rule maybe?

I have no idea. It did strick me though, when you said that the tracking was inaccurate. I would have to agre but, from the IRS's perspective, wouldn't that be better than what an individual can come up with in their tax returns?

Surely a casino with the necessary capabilities to track your play throughout the year would be more reliable than a player declaring their earnings? Also, if you want to declare your earnings and deduct your losses, can't you use your P&L printout from your casino using your players club card?

I kept meticulous track of every single session over the last six months. The record is accurate to within a few hundred bucks (tipping, money spent on site, etc.) The casino lets you see your win/loss statement online, and the one they have on me is inaccurate by several thousand. Sadly, in the bad direction, ie they see that I won more than I actually have.

However, there is a very clear notice accompanying the statement that the casino cannot guarantee its accuracy, that it is up to me, the player, to report accurately to the IRS, and that the statement itself can't be used other than for informational purposes.

I'm eager for Tomspur's lead about the W2g from non-jackpot winnings because I too concluded they aren't given out for low-payout games.

@Ax: noted, and I will keep what you said in mind.

Quote: kewlj

I wonder if this applies to casinos as well? Fremont Casino (downtown) has a big advertisement on the side of the building advertising jackpots of $1199! Clearly this is about avoiding that $1200 threshold that requires a hand pay and paperwork. Isn't that the definition of structuring?

No, this has absolutely nothing to do with structuring. That's the threshold for generating a tax form on a jackpot payout, not a transaction form. Structuring laws are designed to hinder laundering, drug trafficking, and terrorism...not collect taxes. Further, the amount is $10,000 not $1200. A person cannot structure his jackpot wns, and viewing a casino as structuring their payouts is a misinterpretation of the law. This advertisement suggests to the player that the casino will not inform the government of the jackpot. This should be irrelevant since the player is obligated to inform the government of any win.

Advertising a $1199 jackpot is clearly an attempt to circumvent W-2 laws. I assume the IRS doesn't care because it has been around for years.

Quote: arcticfun

However, there is a very clear notice accompanying the statement that the casino cannot guarantee its accuracy, that it is up to me, the player, to report accurately to the IRS, and that the statement itself can't be used other than for informational purposes.

The casino is more interested in recording your "chips off the table" amount than buy-in amounts. Pit bosses have no clue how much people buy-in for, unless of course you only buy-in once. I would guess that for table players 80% of win/loss statements underestimate player losses.

Quote: Sonuvabish

No, this has absolutely nothing to do with structuring. That's the threshold for generating a tax form on a jackpot payout, not a transaction form. Structuring laws are designed to hinder laundering, drug trafficking, and terrorism...not collect taxes. Further, the amount is $10,000 not $1200. A person cannot structure his jackpot wns, and viewing a casino as structuring their payouts is a misinterpretation of the law. This advertisement suggests to the player that the casino will not inform the government of the jackpot. This should be irrelevant since the player is obligated to inform the government of any win.

If this is the case why are employers required to report employee income to the IRS? All income is required to be reported by individuals so there is no need for businesses to report.

Quote: 1arrowheaddr

If this is the case why are employers required to report employee income to the IRS? All income is required to be reported by individuals so there is no need for businesses to report.

To pay employment taxes. And since employees typically make more than $1200 a year, I do not see why this is remotely analogous. If a business can attract persons to independently work for them for $599, the business need not report the person's information. These are completely different laws. The business does not go to jail for failure to comply, it pays a fine. There is no need to report because the law says so; if you still think this is structuring, you are beyond reason.

Quote: Sonuvabish

To pay employment taxes. And since employees typically make more than $1200 a year, I do not see why this is remotely analogous. If a business can attract persons to independently work for them for $599, the business need not report the person's information. These are completely different laws. The business does not go to jail for failure to comply, it pays a fine. There is no need to report because the law says so; if you still think this is structuring, you are beyond reason.

If the casino is advertising jackpots of $1199, it is an effort by the casino to AT LEAST attempt to market to people who are interested in avoiding W-2's/reporting requirements. How is it not? I would liken advertising jackpots of $1199 to advertising independent contractor jobs that terminate once a contractor has earned $599. I think the IRS would be very interested in a business that openly advertises a this arrangement. I don't think IRS cares about the $1199 thing because finding all wage income is much more central to the standard operating procedure of the IRS than penalizing recreational gamblers that probably lose money gambling anyway.

Quote: 1arrowheaddr

If the casino is advertising jackpots of $1199, it is an effort by the casino to AT LEAST attempt to market to people who are interested in avoiding W-2's/reporting requirements.

Yes

Quote: 1arrowheaddr

I would liken advertising jackpots of $1199 to advertising independent contractor jobs that terminate once a contractor has earned $599. I think the IRS would be very interested in a business that openly advertises a this arrangement.

No one wants to pay taxes on slot winnings, there is always buzz about the preference of hitting for $1100 over $1200 at the casino. No one is looking for a temporary job that terminates after earning $599, that is absurd.

Quote: 1arrowheaddr

I think the IRS would be very interested in a business that openly advertises a this arrangement.

So do I because a business is restricted in the amount of money it can spend to hire in help in this manner, and a large company could certainly not employ it's entire workforce in this manner legally, nor in reality.

Quote: 1arrowheaddr

I don't think IRS cares about the $1199 thing because finding all wage income is much more central to the standard operating procedure of the IRS than penalizing recreational gamblers that probably lose money gambling anyway.

They make no categorical distinctions between income, only the layman does. Going after gamblers is economically inefficient because they generally owe less than the cost of pursuing them, and an aggressive stance would decrease revenues generated from casinos. They don't care because it is not illegal. Structuring is not analogous to attempted tax evasion, which seems to be the theme. There is no such thing as attempted tax evasion because the attempt is an element of the completed crime itself and not an inchoate offense. Structuring is not tax evasion.

Did y'all know that some states, including MA and CT, don't allow gambling losses as deductions? That means if you have 50k in winning sessions, and 50k in losing sessions for a net of 0 in gambling income, your tax liability to the state is whatever the tax rate is APPLIED TO THE 50K IN WINNINGS?!!!! And for most people who usually lose money gambling, you are still taxed on every winning session even if you lost overall. This is unlike the federal tax return, where deductions up to the full amount of gambling winnings are allowed.

Quote: arcticfun

Did y'all know that some states, including MA and CT, don't allow gambling losses as deductions? That means if you have 50k in winning sessions, and 50k in losing sessions for a net of 0 in gambling income, your tax liability to the state is whatever the tax rate is APPLIED TO THE 50K IN WINNINGS?!!!! And for most people who usually lose money gambling, you are still taxed on every winning session even if you lost overall. This is unlike the federal tax return, where deductions up to the full amount of gambling winnings are allowed.

Yeah it's dumb. If I end up moving to MA not sure how I will deal with this.

here is my 2 cents on how i think it works.

I was at the wynn a few years ago with a couple of buds. they were in the book watching a BB game. I would buy in at a BJ game for $1,000 -$2,000 play a few hands until I was up (a couple of times I busted) cash out at cage. Go watch the game for a few mins. Rinse and repeat. Everytime I bought in it was with my players card. The last time I tried to buy in (w/my card), pit boss told me if i did he was going to have fill out some form (SAR i think) and didn't really feell like it, so he told me to scram and next time I buy in do it with out using my card.

I think it has to do when you are buying in, not cashing out. My wife works at a jewelry store and if someone comes in and buys >$10k of jewelry with cash they have to fill out one of those forms.

......

Quote: iamthepush

Everytime I bought in it was with my players card. The last time I tried to buy in (w/my card), pit boss told me if i did he was going to have fill out some form (SAR i think) and didn't really feell like it, so he told me to scram and next time I buy in do it with out using my card.
I think it has to do when you are buying in, not cashing out.

The pit boss, in this instance, was probably referring to the Cash Transaction Report (CTR) and not the Suspicious Activity Report (SAR).

There are two different reports that may be filed involving large cash transactions. One is the CTR and the other is the SAR. Banks, brokers and other institutions--including casinos--must file these reports. The requirements for when the CTR must be filed is explicit while the SAR is subject to a good deal of discretion. It is possible the pit boss was thinking of the SAR, but based on my experience, I doubt it.

The CTR must be filed if there is a cash transaction or a series of cash transactions in excess of $10,000--within a 24 hour period. (With casinos, this 24-hour rule may not be totally accurate, since most casinos treat this as their reporting day as beginning and ending at the same time each day--such as 5:00 am.) Casinos have procedures in place to track this--which is why you may find that your cash transactions of a lesser amount are being logged, since you may trigger the $10,000 amount as the result of multiple transactions in the course of the day.

You are wrong if you think this only refers to when you are buying in and not when you are cashing out. In fact, the regulations for filing the CTR refer to both events. If you buy-in for a total in excess of $10,000 within a 24 hour period, then they will file the CTR on you. If they do not have your SS number in the system (with your players information) then you will be asked for your driver's license or other ID and for your SS number. If you should cash out for more than $10,000 within a 24 hour period, then the same thing will happen.

You may manage to slip through the cracks on cashing out if your transactions at the cage are with different cashiers at different times with amounts of less than $2,000 to $3,000 each.

Frankly, I am very surprised at the comments by the pit boss to you. In my experience, as soon as you go over the $10,000 threshold amount, there is no discretion on the part of the casino. They must file the CTR. For example, if you said you made a mistake and you did not intend to buy-in for so much and you ask that part or all of your last buy-in (which put you over the $10,000) be returned to you, the casino is not allowed to do that. Again, in this instance, they must file the CTR.

If you refuse to provide an ID and SS number, then you will not be permitted to play anymore that day.

It is also my experience that casino employees both at the cage and in the pit do not discuss the specifics of filing CTRs and SARs with the customer. Again, I am surprised the pit boss even told you to not use your card so that you can circumvent the $10,000 cash transaction report. I can only assume this pit boss is very lazy and simply does not want to do more than the minimum amount of paperwork.

Besides, not using a player's card will not absolutely insure that you get around the CTR--though it may. Should you buy-in without a player's card, your transaction will still be entered at the table and your additional transactions will be tracked. If surveillance catches the fact that you have gone over the $10,000 amount or, for example, if some other pit boss comes along and suspects that your multiple transactions are approaching $10,000, and a call is made to surveillance to check, then they will still file the CTR.

Incidentally, I have commented before on this subject in some previous posts. Having a CTR filed on you is not necessarily something that must be avoided at all costs. I've had them filed on me many, many times. I have not been audited yet. Then again, my tax returns do reflect my gambling activity.

Quote: Jimbo

You are wrong if you think this only refers to when you are buying in and not when you are cashing out. In fact, the regulations for filing the CTR refer to both events. If you buy-in for a total in excess of $10,000 within a 24 hour period, then they will file the CTR on you. If they do not have your SS number in the system (with your players information) then you will be asked for your driver's license or other ID and for your SS number. If you should cash out for more than $10,000 within a 24 hour period, then the same thing will happen.

If I bought in for $5k and played BJ, left with $5k and went to the cage and cashed in my chips they'd fill out a CRT on me?

Quote: iamthepush

If I bought in for $5k and played BJ, left with $5k and went to the cage and cashed in my chips they'd fill out a CRT on me?

I think that the $10k has to be in the same direction -- either buy-ins that sum to $10k, or cashouts that sum to $10k.

Quote:

If I bought in for $5k and played BJ, left with $5k and went to the cage and cashed in my chips they'd fill out a CRT on me?

No - you need to separate it into buy-ins and cash-outs.

If the sum of all cash buy-ins (not chips!) > 10k over 24 hours, even if multiple transactions are involved, then CTR.
If the sum of all cash-outs (exchange chips for cash at cage) > 10k over 24 hours, even if multiple transactions, then CTR.

If you buy for 7k and cash-out for 8k, no CTRs.

The two responses are correct. You do not add together the cash relating to the buy-in to the cash at the cage when you cash-out in order to determine the "transaction or series of transactions" for the purposes of the CTR. These are separate transactions.

Quote: AxiomOfChoice

I think that the $10k has to be in the same direction -- either buy-ins that sum to $10k, or cashouts that sum to $10k.

when I withdraw more than $10k from my bank they fill out a crt?

Yes, if the 10k is cash.

Quote: AcesAndEights

Yeah it's dumb. If I end up moving to MA not sure how I will deal with this.

Yeah, it is enough to not make me want to gamble for any significant stakes in my home state of Ohio, since they also don't have a deduction for losses. I got royally screwed on my last state tax return.

Quote: teddys

Yeah, it is enough to not make me want to gamble for any significant stakes in my home state of Ohio, since they also don't have a deduction for losses. I got royally screwed on my last state tax return.

Aren't you required to report all gambling winnings, regardless of the location of the casino, on your state return? If you're bending the rules, that's fine, I'm not calling you out as I would do the same in one of these dumb states.