Online Gambling and Cryptocurrency Mailing Addresses for 2026

Posted on February 13, 2026 by Russ

If you have one or more foreign financial accounts and you have $10,000 aggregate in those account(s) at any time during 2024, 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 13, 2026. 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

Bet105
Heritage Sports dba Bet105
support@bet105.ag
San Jose, Costa Rica

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

Bet487
Ragnarok Corporation dba Bet487.org
Pletterjweg 43
Willemstad, Curacao (Netherlands Antilles)

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
C 44378 Msida Ct, 61 First Flr, Msida Seafront
Msida, MSD9043 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

Betway
Betway
9 Empire Stadium St
Gzira, GZR1300, Malta

Betway.mx
Espectaculos Desportivos Fronton Mexico SA de CV dba Betway.mx
Universidad 1571, 2nd floor, Florida neighborhood, Álvaro Obregón District
Mexico City, CP01030, Mexico

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

Bitso
Bitso
Campos Eliseos 400 601B Col. Polanco Reforma México
Mexico City, DF 11530, Mexico

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
Harp Media B.V. dba Bovada
Chuchubiweg 17
Willemstad, Curacao (Netherlands Antilles)

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
11th Flr, East Tower, Lanyon Pl
Belfast, BT1 3LP 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

ClubWPT Gold
Grand Cru Concepts Ltd dba ClubWPT Gold
Arch. Makarious III & Evagorou, 1-7, MISTI3, 1st Fl, Flat 102
Nicosia, 1065, Cyprus

Codere Mexico
Foreign Books, S.A. dba Codere Mexico
Avenida del Conscript 311, colony Lomas de Sotelo, Mayor of Miguel Hidalgo
Mexico City, CP11200, Mexico

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

CoinPoker
Precise IG Solutions B.V. dba CoinPoker
Schottegatweg Oost Unit 1-9, Bon Bini Business Center
Willemstad, Curacao (Netherlands Antilles)

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
Harp Media B.V. dba Ignition Casino
Chuchubiweg 17
Willemstad, Curacao (Netherlands Antilles)

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

Lucky Block
Igloo Ventures SRL dba Lucky Block
Cedula Juidica
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
11th Flr, East Tower, Lanyon Pl
Belfast, BT1 3LP, 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

Sportiumbet Mexico
Operadora General de Entretenmineto S.A. De C.V. dba Sportiumbet Mexico
Calle Pedro Moreno, Número Exterior 1705, Número Interior 3B, Colonia Americana
Guadaljara, Jalisco 44160, Mexico

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.

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Why This Tax Season Is Likely to be Slow and Agonizing for All

Posted on January 29, 2026 by Russ

Matt Metras, a fellow tax professional, shared a chart on X (formerly Twitter) noting IRS personnel cuts by function between January 25, 2025 and December 18, 2025:

I’ll take just three areas that I regularly deal with: Taxpayer Advocate Service (TAS), Taxpayer Services, and Information Technology.  (Overall, staffing is down by over 27%.)

Taxpayer Advocate Service: Staffing at the Taxpayer Advocate Service is down by over 25%.  TAS is where taxpayers (and practitioners) go when problems at the IRS cannot be resolved through normal methods.  We’re seeing more and more such issues, yet due to staffing cuts (a) all TAS submissions must be done in writing (using IRS Form 911)–phone calls are no longer accepted, (b) because of the cuts it’s clear that TAS will take fewer cases (with a result I’m going to note below), and (c) such cases will take far longer to be resolved.

What’s the result going to be from this? Fewer taxpayers are going to get cases resolved, more taxpayers will need to go to Congressional liaisons (which will also decrease normal TAS cases), and both taxpayers and practitioners will be frustrated.

Taxpayer Services: Staffing at Taxpayer Services is down over 21%. This means fewer phone calls will be answered (more courtesy disconnects, where you hear the words, “We’re sorry, but due to extremely high demand in the topic you chose we cannot answer your call at this time; goodbye”), leading to more call volume, more letters/uploads that will have to be responded to, and a degradation of service.  Additionally, expect the response time on IRS notices to lengthen–likely significantly.  Returns will be processed slower, costing the government money (if a refund takes 45 days or longer to be processed, interest must be paid).

Information Technology: Last night, I spoke with my brother. He didn’t initially believe me when I told him a main IRS computer system dates to 1959 (it’s true).  IT staffing is down over 31%.  Does anyone think that cutting IT staffing makes sense when the IRS needs to have more modern computer systems, have systems that keep up with new tax law, and have to effectively administer the tax system?

Let’s add a budget cut to the IRS of $11 billion and a possible government shutdown.  This is a toxic mess that is likely to lead to frustrated taxpayers and professionals.  This will also lead to practitioners getting more phone calls from clients where we have to tell clients, “Unfortunately, there’s nothing we can do.”

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Paying the Piper: Qualified Opportunity Zones

Posted on January 23, 2026 by Russ

When Qualified Opportunity Zones (QOZs) began (with the Tax Cuts and Jobs Act (TCJA) in 2018), they were a way of deferring capital gains received.  This year–the 2026 tax year–is when taxpayers who invested in QOZs will be paying the piper.

The way QOZs work for federal taxes under the TCJA is that if you invest in a QOZ (or a QOZ fund), you are able to defer a capital gain you have until the earlier of selling the investment or December 31, 2026.  (There are specific time-frames and rules on investing in a QOZ.)  If you hold a QOZ for five years (before gain recognition) you get a 10% step-up-in-basis on the deferred amount of gain; if you hold it for seven years, that increases to 15%. (There’s also a permanent exclusion of gain on the appreciation of the QOF investment–but not the deferred gain–if you hold the investment for ten or more years.)  Let’s look at an example:

Russ had a $500,000 long-term capital gain in 2018.  He followed the rules and invested the capital gain in a QOZ in 2018.  He still holds the investment (now worth $700,000) at the end of 2026.  On December 31, 2026, he will recognize $425,000 of long-term capital gain: Russ held the investment for more than seven years so he has a 15% reduction of gain (step-up-in-basis) of $75,000 from the $500,000 deferred gain.

(There’s now a QOZ 2, so to speak.  The One Big Beautiful Bill has a new Qualified Opportunity Zone program for QOZ investments after 2026.  QOZ investments in 2026 will be taxed based on the QOZ rules set in the Tax Cuts and Jobs Act.  I’ll probably post on the new QOZ program late this year.)

If you invested in a QOZ, make sure you understand and prepare for the tax bill that’s coming late this year.

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Hurry Up and Wait 11 Years

Posted on January 20, 2026 by Russ

An interesting Court of Appeals decision came out on Friday: Sirius Solutions, LLLP v Commissioner.  Before getting to the decision and what it means (and does not mean), I wanted to comment about timing of court decisions.

This case deals with the 2014-2016 tax returns of Sirius (filed in 2015 through 2017).  The audit of 2014 was completed, with a report on 2014 issued in June 2020.  (There’s nothing in the Court decision to note when the audit began; however, given the normal three year statute of limitations it likely began in 2016).  Sirius disagreed with the result at audit, and filed a Tax Court petition in September 2020.  (The IRS later ruled against Sirius for 2015 and 2016 in June 2021; Sirius filed a second Tax Court petition in September 2021.  The two cases were consolidated for trial.)  The Tax Court ruled in February 2024 against Sirius.  The Court of Appeals decision was released on January 16, 2026.  That’s about 11 years from filing until a precedential opinion.  It takes a long time for there to be precedential opinions in tax cases.

As for the case, it’s an important one dealing with limited liability partnerships and self-employment tax.  Sirius filed three returns showing various amounts of income, but no self-employment income for their limited partners.  (The limited partners were active in the business.)  The IRS’s position is that only passive limited partners (partners not active in the business) could avoid self-employment tax on the income.  The Tax Court ruled (at the request of Sirius) that a prior Tax Court case, Soroban Capital Partners LP v Commissioner, bound the court to rule against Sirius.  The 5th Circuit Court of Appeals did not agree.

The 5th Circuit’s ruled that Limited Liability Limited Partnerships (LLLPs) are a creature of state law; and that Congress didn’t write the law on self-employment tax to include income attributable to LLPs.  (Do note that guaranteed payments made to limited partners are subject to self-employment tax.)  The IRS could appeal this ruling (either asking the full 5th circuit to rule on it en banc or appeal to the Supreme Court) but for now Sirius Solutions is the law in the 5th Circuit (Louisiana, Mississippi, and Texas).

Before I get into an interesting corollary from this ruling I do need to let readers know that both the IRS and Tax Court are free to continue ruling against limited partners who follow the Sirius Solutions decision in states not covered by the 5th Circuit.  And I expect both to do so (until other circuits opine on this decision, or the Supreme Court rules).

The corollary relates to Limited Liability Company (LLC) members.  I’m such an individual.  Am I (or any other LLC member) subject to self-employment tax on my share of the net income of my business?  I haven’t fully researched this, but it’s on my agenda.  When this portion of the Internal Revenue Code was enacted (Section 1402(a)), Limited Liability Companies weren’t a thing (as far as I know).  The 5th Circuit opinion specifically says (in footnote 1), “…[W]e do not discuss whether members of another entity, such as an LLP or LLC, may also qualify for the limited partner exception.”  It makes for interesting speculation.

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Can a Gambling Session Last a Year?

Posted on January 9, 2026 by Russ

The One Big Beautiful Bill (OBBB) added both good and bad for gamblers in the Tax Code. One item that’s bad is that gambling losses are limited to 90% of the gambling losses incurred.  Professor Bryan Camp (a professor of tax law at Texas Tech) speculated that it might be possible to use an establishment-based session for a full year (your play at, say, the Wynn would be one session; your play at Bellagio would be another, etc.).  Is that realistic?  Will the IRS–and, more importantly–the courts agree with that?

First, no one will definitively know the answer on this for years.  Until there are precedential court rulings a definitive answer is impossible.  The IRS will, of course, interpret the OBBB 90% loss limitation in some manner.  (It’s quite possible at audit that each IRS Revenue Agent will take his or her own position, and they could differ.)  But IRS positions are not definitive; it will be what courts, in precedential cases, decide.  And not all court cases are precedential.  Realistically, the earliest we would see a precedential court case is 2029; it’s far, far more likely we’re looking at 2030 or later, potentially several years later.  

The Tax Code is law (passed by Congress, signed into law by the President).  Nowhere in the Code is a definition of “session.”  In City of S.F. vs EPA (145 S. Ct. 704, 715 (2025)), the Supreme Court said that you should use the “most natural reading” of a statute to determine its meaning.  The Tax Court noted that when a term is not defined in a statute, “…[W]e must discern its ordinary meaning….” (Savage v Commissioner, 165 T.C. No. 5, citing Food Mktg. Inst. v Argus Leader Media, 139 S Ct. at 2362)

A legal definition of a session is, “…a fixed period of time during which a governmental body, such as a court or legislature, conducts its official business.”  Another online definition is “a specific block of time dedicated to something.”

Let’s consider Russ, an amateur gambler.  He plays poker at the Wynn Casino on January 11th, winning $500.  On June 10th, he again plays poker at the Wynn casino and loses $400.  That’s his only gambling activity at the Wynn during the year.  Will a court accept that he has $100 of gambling winnings for purposes of noting gross gambling winnings on his tax return? (Remember, an amateur gambler must separate out his gambling winnings and losses on his tax return; wins are “Other Income” and losses are an itemized deduction on Schedule A.)

That’s not going to occur: this fails the smell test.  Russ played two distinct poker sessions, and there are two distinct results for the year.  Do you think any court will accept the idea that Russ has one poker session during the year?  I don’t.

But what about gambling as video poker or slots?  Can Russ net his gambling winnings at one casino (say, the Wynn) during the year? Let’s assume that he has only gambled at the Wynn during the year.  Let’s assume Russ gambles twenty days out of each month, has both winning and losing sessions.

Unfortunately, the same problem arises.  It again fails the same smell test.  No court is going to consider that he only had one gambling session during the year.

Recently, a different tax professional suggested that two Tax Court cases, Shollenberger v Commissioner and Boneparte v Commissioner, allow this and using the session method generally.  (Both are cited in Professor Camp’s article.)  There are problems with this–and another decision, Park v Commissioner, provides some additional guidance.

As to using the session method for gambling, I agree completely that this is allowed.  Not only does Shollenberger explicitly allow this, a later appellate case, Park v Commissioner, also explicitly allows this.  The decision in Park was written by current Supreme Court justice Brett Kavanaugh.

The Boneparte case deals with a taxpayer who filed as a professional gambler, but the IRS challenged his professional status.  The Court agreed with the IRS that Mr. Boneparte was an amateur gambler.  The next issue was could Mr. Boneparte deduct gambling losses–and, if so, how to determine his losses.

The Court allowed Mr. Boneparte (for the year in question, 2013) to calculate his gambling losses by casino establishment.  Professor Camp makes the argument that since the IRS allowed the gambling losses by establishment here that the IRS will allow establishment-based losses under the OBBB.  That’s just not the case.

The IRS, Court, and the taxpayer all agreed his gross winnings for the year were about $18,000.  The Court (and the taxpayer) agreed that the taxpayer had a losing year.  Consider the algebraic formula for Net Winnings for a year:

Net Win = Gross Win less Gross Losses (or N = G – L)

Here, we know that N is less than zero. But in tax, net winnings cannot be less than zero; thus, it became zero.  In algebra, if we know two of three variables, we can solve for the third:

N = G – L
$0 = $18,000 – L
L = $18,000

This is what the Bonaparte decision is about; determining the taxpayer’s gambling loss for 2013.  Given the tax law in effect for 2013, his gambling losses for tax purposes since he was a losing gambler must be $18,000.  Unfortunately, this ruling is not the same as allowing establishment-based win/losses in the future.

We now must return to Shollenberger.  Unfortunately, this case contains language specifically not allowing a taxpayer to net a year’s gambling together:

To permit a casual gambler to net all wagering gains or losses throughout the year would intrude upon, if not defeat or render superfluous, the careful statutory arrangement that allows deduction of casual gambling losses, if at all, only as itemized deductions, subject to the limitations of section 165 (d).

What about using per establishment?  Given that Shollenberger doesn’t allow netting for a year, then you wouldn’t be able to net per year for establishment. Well, Shollenberger is looking at amateur gamblers; we can make the argument it doesn’t apply to professional gamblers.

Sure, an argument can be made–but it’s likely a losing argument.  A court is likely to look at Shollenberger and apply that to professional gamblers under the new law.  Allowing netting for a year for professional gamblers would “…intrude upon, if not defeat or render superfluous, the careful statutory arrangement that allows deducti[ng]…gambling losses….”  This is a far more likely conclusion than allowing establishment-based netting for a year.

Then, can anything be netted?  Most likely, yes–especially for online gambling.  Another court case, here from the Court of Appeals for the District of Columbia Circuit (the second highest court in the US), is Park v Commissioner.  Park specifically allows per session netting of wins and losses.  A session of slot play can be netted.  For amateur gamblers, it’s possible that everything can be netted for one session within a casino.  Say Russ goes into the Wynn, plays video poker (winning $200), craps (losing $100), and poker (losing $100) before calling it a day.  A literal reading of Park allows this to be netted (resulting in a session win of $0).

Similarly, online play for a day likely can be netted.  It’s analogous to someone walking into and out of a casino.

What if we don’t redeem our casino chips, cash out vouchers (from slot machines), etc. and do this all in one day? Then won’t I have just one session? That, too, won’t work.

First, casino chips are considered a cash equivalent.  If you play poker and win casino chips but don’t turn them into cash, you still have winnings that day.  Second, the rules of constructive receipt state that if you could have made a deposit, you have income when you could have made the deposit.  There’s no workaround here.

We’re left with an inescapable conclusion: Session-based accounting, and keeping good records thereof, is the only way to minimize the damage of the new 90% loss limitation.  Using year-long establishment-based results will not work.  (The better answer is, of course, for the law to be repealed.)

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When Will 2026 Tax Season Open? It’s Official: Monday, January 26th

Posted on January 8, 2026 by Russ

Earlier this week, the IRS announced that business tax return efiling will open next week (this came out in an email).  No date has been given yet for individual (personal) tax returns, but I now expect it to open the last week of this month (which is typical).  UPDATE: The IRS announced this morning that Tax Season will open on Monday, January 26th.

My software company currently shows a January 26 date (their estimate):

This would be normal for the IRS, and is good news. There were a lot of changes made in tax law for 2025 (courtesy of the One Big Beautiful Bill (OBBB)), and the IRS at one time quoted a mid-February start date.  But that does not mean you can file your return on January 26th.  

First, you need to wait for all of your tax documents to file.  That brokerage account with $5 of dividends? Yes, your tax professional needs that 1099.  That K-1 from a partnership with $2 of income that won’t be ready until June? Yes, your tax professional needs to see all pages of every K-1 package.  Finally, many forms will not be ready immediately.  My software company notes that they don’t expect Form 3468 (Investment Credit) and Form 172 (Net Operating Losses) to be ready until mid- March.  The OBBB made many changes, and these all have to be worked through by the IRS and software companies.  I also need to point out that many state forms might not be ready immediately.

So, kudos to the IRS on working through a difficult update.  And hopefully this Tax Season will go smoothly for taxpayers, tax professionals, and the IRS.

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It’s Time to Issue 2025 Form 1099s

Posted on January 7, 2026 by Russ

It’s time for businesses to send out their annual information returns. These are the Form 1099s that are sent to to vendors when required. Let’s look first at who does not have to receive 1099s:

  • Corporations (except attorneys);
  • Entities you purchased tangible goods from;
  • Entities you purchased less than $600 from (except royalties; the limit there is $10); or
  • Where you would normally have to send a 1099 but you made payment by a credit or debit card (or other third-party processor that issues a Form 1099-K to recipients)

Otherwise, you need to send a Form 1099 to the vendor. The best way to check whether or not you need to send a 1099 to a vendor is to know this before you pay a vendor’s invoice. I tell my clients that they should have each vendor complete a Form W-9 before they pay the vendor. You can then enter the vendor’s taxpayer identification number into your accounting software (along with whether or not the vendor is exempt from 1099 reporting) on an ongoing basis.

Form 1099-NECs have a filing deadline of February 2, 2026 (for reporting 2025 nonemployee compensation). Form 1099-MISCs are used for all other 1099 reporting except interest, dividends, capital gains, etc. Payments of rent, royalties, advertising, crop insurance proceeds, substitute payments in lieu of dividends, attorney proceeds, other income (including gambling winnings not reportable on a Form W-2G), and nonqualified deferred compensation are just some of the items reported on a Form 1099-MISC.

Remember that besides the 1099 sent to the vendor, a copy goes to the IRS. If you file by paper, you likely do not have to file Form 1099-MISC with your state tax agency (that’s definitely the case in California). However, if you file 1099s electronically with the IRS you most likely will also need to file them electronically with your state tax agency (again, that’s definitely the case in California). It’s a case where paper filing might be easier than electronic filing.  NOTE: If you issue 10 or more Form 1099s, you must electronically file the 1099s.  You can do this yourself (you can register for the IRS’s IRIS system, preregistration is required), through various online systems that will charge you a nominal fee per 1099 (typically, $5-$15 per 1099), or most tax professionals will issue 1099s for their clients.

IMPORTANT: You may also need to file your 1099s with a state tax agency.

If you wish to file paper 1099s, you must order the forms from the IRS. The forms cannot be downloaded off the Internet. Make sure you also order Form 1096 from the IRS. This is a cover page used when submitting information returns (such as 1099s) to the IRS.

Note also that sole proprietors fall under the same rules for sending out 1099s. Let’s say you’re a professional gambler, and you have a poker coach that you paid $650 to last year. You must send him or her a Form 1099-NEC. Poker players who “swap” shares or have backers also fall under the 1099 filing requirement (issuing form 1099-MISC).

Remember, the deadline for submitting 1099-NECs for “Nonemployee Compensation” (e.g. independent contractors) to the IRS is now at the end of January: Those 1099s must be filed by Monday, February 2nd.  (We get two extra days this year because January 31st falls on a Saturday.)

Here are the deadlines for 2025 information returns:

  • Monday, February 2nd: Deadline for mailing most 1099s to recipients (postmark deadline);
  • Monday, February 2nd: Deadline for submitting 1099-NECs for Nonemployee Compensation to IRS;
  • Monday, March 2nd: Deadline for filing other paper 1099s with the IRS (postmark deadline);
  • Monday, March 16th: Deadline for mailing and filing Form 1042-S; and
  • Tuesday, March 31st: Deadline for filing other 1099s electronically with the IRS.

Remember, if you are going to mail 1099s to the IRS send them certified mail, return receipt requested so that you have proof of the filing.

Also note that most 1099s must be mailed to recipients. Mail means the postal service, not email. The main exception to this is if the recipient has agreed in writing to receiving the 1099 electronically. I consider this the IRS’s means of trying to keep the Post Office in business.

Finally, for the 2026 tax year the 1099 threshold increases to $2,000 from $600 and it’s indexed for inflation thereafter.  That should cut down on some of the 1099s that must be issued.

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It’s Time to Start Your 2026 Mileage Log

Posted on January 6, 2026 by Russ

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 146,501). 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 “2026 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:

1/7 146900-146935 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 $0.725/mile, the 35 miles in this hypothetical trip would be worth a deduction of $25. That deduction does add up. (Just last week the IRS announced that the 2026 standard mileage rate is $0.725/mile.)

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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The 2025 Tax Offender of the Year

Posted on December 30, 2025 by Russ

Many are called; few are chosen. And I strongly advise you not to choose this route; however, every year my advice is ignored. Yes, it’s time for the annual award I give, the Tax Offender of the Year.  As usual, there are many deserving candidates but there can only be one winner.

A reader nominated Minnesota Governor Tim Walz and Minnesota Attorney General Keith Ellison for turning a blind eye towards the rampant fraud in the state.  If you haven’t seen the video done by citizen journalist Nick Shirley, watch it.  You will be disgusted. Yes, it’s likely a few of the organizations are real (and just happened to be closed on the day that Mr. Shirley visited), but the denial by Minnesota officials looks to be, shall we say, learing.  Unfortunately, this is not a case of tax fraud (yet), just ordinary fraud.

Another nomination went to the 324 defendants charged in the “2025 National Health Care Fraud Takedown.”  The alleged fraud is over $14 billion, definitely enough to get my attention.  But once again we’re looking at mostly health care fraud, not tax fraud.

Not eligible was a very large French tax evasion case against UBS.  UBS Group AG agreed to pay an €835 million (nearly $1 billion) settlement in long-running tax evasion case in France. French officials alleged that UBS helped French clients hide funds in Switzerland.  Tax evasion is worldwide; however, I look at only US tax evasion and related crimes for this award.

In third place we find John Walker.  Mr. Walker was the owner of Hansen Helicopters, and his company built helicopters that weren’t airworthy.  He took discarded frames, counterfeit parts, and, voila!, a sort-of-working helicopter.  These helicopters were used by the tuna industry but caused injuries and death.  Mr. Walker also used “at least 48 shell companies…to operate his business.”  Both Mr. Walker and his business were found guilty in 2022 on 110 counts involving conspiracy, aircraft parts fraud, wire fraud, and money laundering.  Mr. Walker forfeited over $58 million (representing the proceeds of aircraft and wire fraud) plus paid $11.8 million (the amount involved in money laundering).  Mr. Walker was sentenced this past September to 33 years and 9 months at ClubFed.

Second place went to Rafael Alvarez of the Bronx, New York.  Mr. Alvarez was known as “The Magician;” he made your taxes vanish.  His business, ATAX New York, prepared around 90,000 tax returns from 2010 through 2020 (definitely a high-volume practice). Of course, his methods were less than magical: phony itemized deductions, capital losses, business expenses, and tax credits; a true potpourri of non-magical fraud.  Mr. Alvarez was ordered to pay $145 million in restitution, forfeit $11.84 million in fraudulent proceeds, and will spend four years at ClubFed.

Credit Suisse (formally, Credit Suisse Services AG) is a unit of UBS; it’s one of the largest Swiss Banks.  It was founded in 1856, and was acquired by UBS in May 2024.  For this story, we must go back in time to the first decade of this century.

The IRS, Treasury Department, and Justice Department filed a criminal indictment in 2014 alleging that Credit Suisse AG conspired and assisted US taxpayers through 2009 by creating sham entities, preparing false forms regarding foreign accounts, destroying records, and basically covering up foreign (to the US) financial accounts in violation of the federal conspiracy law.  Credit Suisse settled by pleading guilty to conspiracy, paying $2 billion, respond to US requests for information, close recalcitrant account holders, and implement procedures with its employees so that this would never happen again.  Surely $2 billion made sure this never happened again, right?

Well, Singapore is a long way from Switzerland (about 6,400 miles).  Apparently, the 2014 plea agreement didn’t make it into the hands of the Singapore subsidiary.  Even worse for Credit Suisse, the US figured out that basically the same things noted in the first criminal indictment were happening in Singapore:

  • Falsifying bank records;
  • Falsifying US account owners as not US persons;
  • Fictitious paperwork removing the US owners from filings;
  • Using a Swiss lawyer as a nominee for 104 accounts;
  • Servicing more than $1 billion of US accounts without full documentation of tax compliance;
  • Held $2 billion in US assets without adequately identifying the US owners; and
  • Transferring paper ownership of an account to an alleged sham Swiss trust company.

The alleged activity occurred from 2010 into 2023.  It would be one thing if the activity stopped in 2014 (as it should have); it’s quite another to go nine more years doing things you said you wouldn’t do in a plea agreement you voluntarily signed in 2014.

And it’s not just the $2 billion I noted above; Credit Suisse Services AG pleaded guilty to hiding more than $4 billion in at least 475 accounts.  As part of the plea agreement, Credit Suissse agreed to pay $510,608,09 in penalties, restitution, forfeiture, and fines and will also fully cooperate in US investigations of the accounts.

There is nothing wrong with having a non-US financial account. But if you do, you must disclose the account in up to three ways: on Schedule B of your tax return, on an annual FBAR filing (Form 114 with FinCEN), and on Form 8938 of your tax return.  There are various thresholds for reporting, and there are extreme penalties for willful non-reporting.  As I tell clients, “Just file the FBAR.”

As for Credit Suisse, presumably I won’t have to write (in the future), “The third time is the charm.”  I have a feeling the US Department of Justice really expects Credit Suisse (and UBS) to have learned their lesson here; only time will tell if that’s the case.

That’s a wrap on 2025.  I wish you and yours a Happy, Healthy, and Prosperous New Year!

 

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Brockman Estate Settles for $750 Million

Posted on December 29, 2025 by Russ

Robert Brockman “won” the 2020 Tax Offender of the Year (an award you really, really don’t want to win); he passed away in August 2022.  Mr. Brockman won the award for allegedly committing a billion dollar tax fraud.

While his criminal indictment ended when Mr. Brockman’s life ended, the civil case (the IRS attempted to recover $1.4 billion) continued.  Last week, Mr. Brockman’s estate settled with the IRS; the estate agreed to pay $465 million in back taxes and $294 million in penalties for the 2004-2018 tax years. It’s a lot easier to simply pay your taxes (and it’s definitely financially prudent to do so).

This reminds me that we will be announcing the winner of the 2025 Tax Offender of the Year award later this week.  Here are the previous winners:

2024: Mark Scott
2023: Lev Derman et. al.
2022: Kevin Kirton
2021: Oleg Tinkov
2020: Robert Brockman
2019: Lawrence R. Gazdick, Jr.
2018: California’s Train to Nowhere
2017: State and Local Pension Crisis
2016: Judge Diane Kroupa
2015: Kenneth Harycki
2014: Mauricio Warner
2013: U.S. Department of Justice
2012: Steven Martinez
2011: United States Congress
2010: Tony and Micaela Dutson
2009: Mark Anderson
2008: Robert Beale
2007: Gene Haas
2005: Sharon Lee Caulder

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