The regulatory requirements if required do put quite a damper on this plan. But wouldn't coinbase, Mtgox and the banks technically be performing the exchange portion of this transaction? We would simply be using their services. What's the difference between this process and me simply buying coins on coinbase, selling them directly on Mtgox and wire to my US bank , besides taking months for an withdrawal to process? If we keep records of all cash flow and prove to the IRS were paying appropriate tax, I don' understand the issue.
http://www.fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.html
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Definitions of User, Exchanger, and Administrator
This guidance refers to the participants in generic virtual currency arrangements, using the terms "user," "exchanger," and "administrator."6 A user is a person that obtains virtual currency to purchase goods or services.7 An exchanger is a person engaged as a business in the exchange of virtual currency for real currency, funds, or other virtual currency. An administrator is a person engaged as a business in issuing (putting into circulation) a virtual currency, and who has the authority to redeem (to withdraw from circulation) such virtual currency
This guidance refers to the participants in generic virtual currency arrangements, using the terms "user," "exchanger," and "administrator."6 A user is a person that obtains virtual currency to purchase goods or services.7 An exchanger is a person engaged as a business in the exchange of virtual currency for real currency, funds, or other virtual currency. An administrator is a person engaged as a business in issuing (putting into circulation) a virtual currency, and who has the authority to redeem (to withdraw from circulation) such virtual currency
By my reading, your proposed actions would qualify you as an exchanger as "a person engaged as a business in the exchange of virtual currency for real currency, funds, or other virtual currency". Basically, this covers any buying and selling for profit which is why this guidance has had such a chilling effect on US traders. Technically, here in the "land of the free" we are only allowed to use virtual currency as a payment method. Yet, somehow, money is speech, so we can't restrict campaign donations by corporations.
Again, I am not a lawyer, so please seek expert advice from a lawyer and or accountant.