This will be a very technically complex blog, one that will be particularly challenging for any baby boomer. I suggest that you consult with an expert – your teenage son or daughter! We’ll be looking at the world of online games such as Second Life (“2L”) and World of Warcraft (“WoW”). Online gaming is a multi-billion dollar industry – but one I’m willing to bet fewer than a handful of you have ever been involved with (online poker does not count). I’ll use a Monopoly analogy whenever possible to illustrate the economics of the industry. For the benefit of you old fuddy duddies!
Online games are like Monopoly, though major differences exist. In an online Monopoly game, a player can leave the game and return when she wants. When she returns, she’d have the same money and property as when she left. Online games do not really end or have a winner – players keep playing for love of the game and the game continues for as long as geeks, er, player want to keep playing. There are games being played right now that have literally gone on for years and show no sign of ending. Players may quit, but a new player will just join in. Casual players – like your children – may play ten hours per week as a relatively low cost and safe form of entertainment.
In 3rd world countries, there are people who literally make their living playing virtual games. And, they sell their Monopoly winnings to casual players with a lot of disposable income in the real world, but less in the virtual world. Imagine Chang, a 12-year old boy in China, plays Monopoly 12 hours per day for a week, passes Go hundreds of times and earns One Billion Monopoly dollars. He sells the Monopoly money to a California wholesaler for $10,000 (that’s US Dollars, if I’ve lost you), who marks it up 50% and sells it to recreational players in the US, from sea to shining sea. Real transactions – people pay real money for Monopoly money. Selling fake money for real money is a global, billion dollar industry!
2L has its own currency, the Linden dollar (L$). L$ can be used to buy, sell, rent or trade land or goods and services with other users. Virtual goods include buildings, vehicles, devices, animations, real properly (well, fake real property if you know what I mean), jewelry, and works of art. Services include “camping”, wage labor, business management, entertainment and custom content creation. L$ can be purchased using US Dollars and other currencies on the LindeX exchange provided by Linden Lab. According to Linden Lab, about 64.000 users made a profit in 2L in February 2009. Hundreds of 2L entrepreneurs have earned profits over $1.0 million per year!
Linden Lab plays the role of the central bank and can increase or decrease the money supply…just like our own central bank. Its primary goal is to keep the exchange rate stable, and incredibly, the exchange rate between US dollars and Linden dollars is more stable than that between US dollars and Euros! As long as virtual items are in demand and companies are careful about controlling the money supply, virtual worlds have the potential to become tax havens. Wow!!!!
I spoke to a tax partner at a local CPA firm about virtual gaming, and I got a real education. He is a great guy and well ahead of the curve on such things. When we spoke, he mentioned that the IRS has not issued any guidance on the tax issues on virtual transactions. But in the current economic climate, where federal and state governments are fighting for every nickel they can get their hands on, you can bet that this will change. Some of the issues raised are below. This sounds like it comes from “The Onion” or another satirical page….I assure you these issues are real. The next few paragraphs are his words, not mine:
Income Realization - When is income recognized from virtual transactions? Is it as simple as when real money changes hands? Having Monopoly money is not taxable….but selling it for real money is. And what makes money real in the modern economy? If a person “earns” monopoly money in a 40 hour week, is it earned and therefore taxable when won…or when sold? If you earn it for the intent of selling, it can be argued that the Monopoly money is taxable when earned, right?
Nexus – Consider our pal Chang whom I described above. The transaction took place in the virtual world…but where can it be considered to happen in the real world? Can the IRS tax Chang? How about its equivalent in China? Can Massachusetts tax the California wholesaler when he sells to a Massachusetts resident? Is Governor Patrick reading this? If the server is located in Florida, can Florida’s DOR tax everybody?
Generational Transfer – Accounts can be shared by a parent and a child. A dedicated player could earn millions of Monopoly dollars worth tens of thousand in real dollars. Is the value of the Monopoly money includible in the parent’s estate? If Pops bought the account, the accumulated Monopoly money probably belongs to him even if the child won most of the money.
Do Lindens meet the definition of functional currency? Would a company with 2L operations report in Lindens? There are businesses that engage in second life commerce and have substantial operations…and audited financial statements.
I kind of laugh at those questions – but they actually are serious. And – BILLIONS of dollars are at stake.
My questions for you:
When do you think the transaction is taxable?
There are companies with 2L operations…should their division record activity in L$ and translate to US dollars?
Would you consider investing your 401-K in L$ if this were legal and offered the same tax advantages?
Would you consider using 2L to transfer wealth to your children?
Do you think it’s wrong that only one company makes the game Monopoly?