Very helpful ... clarifies that a gaming day may either be defined as a standard calendar day, or as a 24-hour time period consistent with the accounting period of the gaming establishment.
Note, however, that this "rule" is narrowly focused to address casino reporting of player payouts to the IRS. It doesn't address the method by which players should account for their play when filing. (As of the date of this rule issuance, Notice 2015-21 still stood as applicable guidance for tax reporting for players.)
The document explains that there was consideration given to making this rule consistent with Notice 2015-21, to facilitate reporting by players under the proposed "safe harbor" rules within that Notice. However, concerns surfaced in comments on this Rule and as a consequence "final regulations do not adopt the proposed rules for electronically tracked slot machine play" (i.e. Notice 2015-21)
This should be taken to mean that there are inconsistencies in the reporting by mandated for casinos under this Rule and the guidelines to players contained in the Notice 2015-21 proposals. For this reason, I'll maintain that there is some audit interpretation risk in filing according to the proposed guidelines in Notice 2015-21 (i.e., until adopted, the guidelines don't serve as a "safe harbor" and are subject to potential challenge during an audit).
Note, again, I'm unable to find anything suggesting that a rule adopting the provisions of Notice 2015-21 has been approved.
(disclaimer: I'm a professional corporate financial analyst, with an extensive accounting background ... not a certified tax or accounting professional. All remarks should be taken in that light.)
---In vpFREE@yahoogroups.com, <kentq@...> wrote :
The final rule clarified what a gaming day can be:
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