Gambling laws vary greatly around the world, with each individual jurisdiction having its own specific rules and regulations in place. In the US and Canada, laws can vary across different states and provinces, so what is permitted can change almost from one town to the next. The laws in Canada are generally more relaxed and permissive than those in the US, although changes to the law which came into force in May 2018 have allowed betting on sports and online casinos in many US states where previously the practice was banned.
For gamblers who win, one of the major differences between US and Canadian law is how much of the win the player gets to take home. Gambling wins are not taxed in any brick and mortar or online casino in Canada, meaning any profits made go straight into the player's pocket. In the US things are very different as gambling wins over certain thresholds count as taxable income. Exactly how much tax is due and at what point it has to be paid varies depending on the amount won, the nature of the game being played and whether the winner is a US citizen or foreign tourist. As a general rule of thumb, most players who win any significant amount can expect to hand over between of that amount to the IRS. Land-based casinos in many states simply withhold the tax percentage and provide the winning player with the correct tax form to fill in. Online casinos are relatively new to most areas of the US so rules may vary, but any income earned is still taxable and should be reported.
Online casinos in Canada are not legally allowed to be operated by Canadian citizens. Much like in New Zealand, while local residents are banned from operating online casinos, there are no laws preventing offshore casinos offering services in Canada or preventing Canadians from using those services. Canadian law only allows gambling at licensed premises or on licensed websites and does not provide licenses for online casinos. Casino gambling itself is highly popular in Canada and there are close to 90 licensed brick and mortar casinos for citizens and tourists to choose from, as well as online services operating from areas such as Malta and the UK.
US citizens are also able to access offshore online casinos, but this can be made more complex depending on the specific rules regarding gambling in the state. Some jurisdictions make it difficult for citizens to access any form of online gambling by restricting payments, in line with the 2006 Unlawful Internet Gambling Act. While regulations are beginning to relax almost everywhere, visitors to the US should be careful to check the legislation in the state they are visiting before attempting to access any online casino or other form of online gambling.
Not all states in the USA have legalised online gambling, so visitors must check the regulations of the state before playing.
Canadians typically have access to a better selection of online casino games than their American counterparts, mainly due to the number and quality of software providers used by offshore websites. Providers aim to differentiate their site by offering a variety of games and features such as live casino to attract players and be known as the best . Many of the top iGaming software brands do not yet have licenses to operate in the US or sell their games and software to US-based casinos. However, some of the more progressive states in terms of embracing new gambling regulations, which currently include New Jersey, Nevada and Colorado, are gradually beginning to open the gates to more international game developers.
While individual players do not have to pay any tax on their gambling wins in Canada, casinos and bookmakers do pay tax and generate revenue for the country. Between May and September 2019, the rose from $2.51 billion to $2.65 billion. New Jersey, one of the first US states to fully embrace new gambling laws and provide casinos and sportsbooks to citizens and visitors, saw the online casino industry bring in almost $85 million for the month of August 2020. This represents an increase of 120.9% compared to the same month in 2019. Online sportsbooks in New Jersey reached revenues of $34.3 million, from total bets of $602 million.
The numbers show that legalised gambling can be highly beneficial to the economy of the country or state, bringing in millions in taxable revenue every single month. Canada's gambling industry is already booming, and the relaxation of the laws in the US makes it look like several states are set to follow. As regulations are changing all the time, gamblers in the US should be more careful about where and how they gamble, checking state laws before committing any money.
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