Originally Posted by Lottery Larry
My understanding was similar to TeflonDawg's
So, players would be able to retroactively claim a lack of constructive receipt, once Black Friday hit? Even though they'd had access for withdrawals before then?
That sounds too.... reasonable, to be an IRS ruling.
Black Friday taught us that Full Tilt was $330 million short on funds owed to players in April 2011. So, theoretically, had all U.S. and non-U.S. players requested full withdrawals from their accounts immediately before Black Friday, many players would not have been paid.
These circumstances presented a "substantial doubt" that players with winnings in their FTP accounts immediately before BF would not actually receive their funds. Thus, no constructive receipt with respect to those winnings.
At least that's the argument. It's one interpretation of applying the law to the facts. The IRS has not provided their view one way or another.