W-2G cage TIN capture procedure

Template from tincompliance.com. A written procedure for taking a winner’s name, address and TIN at the cage before a reportable payout. The procedure, followed and documented, is what Chief Counsel accepted as an initial solicitation at the time of payment in CCA 201234025, which stands in for the annual solicitation and supports reasonable cause when a Notice 972CG lists W-2G mismatches. Adopt it with your own titles, systems and thresholds, and have gaming counsel and compliance review it.

Form W-2G: cage procedure for name, address and TIN capture

[Casino legal name], EIN [00-0000000]. Effective [date]. Owner: [title]. Reviewed each December against the Form W-2G instructions for the coming year.

1. When this procedure applies

A W-2G is prepared before any payout that meets the reporting threshold for the game for the year of payment. For 2026 payments: $2,000 or more from a slot machine, bingo or keno (keno net of the wager); $2,000 or more from other wagers where the proceeds are at least 300 times the wager; more than $5,000 net of the buy-in from a poker tournament. Promotions, drawings and tournament prizes that are not wagers are 1099-MISC box 3 items handled by [department], not by this procedure.

Regular withholding at 24 percent applies to proceeds over $5,000 from sweepstakes, pools, lotteries and 300-to-1 wagers regardless of TIN. Backup withholding at 24 percent applies to slot, bingo and keno winnings only when the winner gives no TIN or a TIN with the wrong number of digits (CCA 201246028); a name and TIN pair that later fails the IRS match is a CP2100 item, not a reason to withhold at the cage.

2. Steps at the cage

1. Verify identity with two forms of identification, at least one government-issued with a photograph. Record the type, number and expiration of each on the W-2G log.
2. Take the winner’s legal name exactly as it appears on the identification, the current address, and the TIN. The TIN comes from a Social Security card, an ITIN letter, a tax document showing the number, or the verified players club record; a number given from memory is recorded as unverified and the winner is asked for the document before the next payout.
3. Have the winner sign the W-2G (or a Form W-9) certifying the TIN. The signature line is the certification; a W-2G without it is an unsolicited TIN for penalty purposes.
4. Winner gives no TIN, or a number with the wrong number of digits: pay net of 24 percent backup withholding, show the amount in box 4, and record the refusal on the log. Do not hold the payout.
5. Winner presents foreign identification or says they are not a U.S. person: stop the W-2G. The payout is a Form 1042-S item withheld at 30 percent from the first dollar unless the winner provides a Form W-8BEN with a treaty claim and the game is one the statute exempts (blackjack, baccarat, craps, roulette, big-6). Route to [title]. A W-9 from a person presenting a foreign passport is a reason to doubt the certification (Park v. Commissioner).
6. Check the state self-exclusion and voluntary exclusion lists before payment. Winnings the state requires the casino to pay over are not the patron’s winnings and get no W-2G (CCA 201433015); record the forfeiture instead.
7. Enter the name, address and TIN into [casino management system] the same day. The system submits the pair to IRS TIN Matching in the nightly batch; a mismatch result is routed to [title] for a corrected TIN request from the patron at the next visit, and the log shows the request and the date.
8. Supervisor review: a shift supervisor initials each W-2G log entry over $[amount] and every entry with a refusal, a foreign winner or an exclusion check.

3. The W-2G log

4. Deposits, reconciliation and retention

• All gambling withholding, regular and backup, is deposited on the Form 945 schedule by calendar day. A gaming day that crosses midnight may be used only where it deposits sooner than the calendar-day rule requires (CCA 202449014).
• Box 4 totals on the year’s W-2Gs are reconciled to Form 945 line 2 before either is filed.
• Before the January filing, every W-2G with a TIN Matching mismatch is reviewed and a corrected TIN solicited; the file is filed with the best information held.
• The log, the signed W-2Gs or W-9s, the ID records and the TIN Matching results are retained for [four] years after the filing year and are the response file for any Notice 972CG.

5. Notice 972CG response

When a Notice 972CG lists W-2G name and TIN mismatches, the response states that the TIN was solicited at the time of payment under this procedure, attaches this procedure, the log entries and the signed certifications for the listed returns, and the withholding deposits for the refusals. That is an initial solicitation at the time of payment and an exception to the annual solicitation requirement (CCA 201234025); a 972CG is a penalty notice, not a B-Notice, and no backup withholding notices are owed in response to it (CCA 201246028).

Approved: [name], [title], [date].