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$100 Incentive Bonus-Disclose IRS Report on Ad?

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Question: 
We are offering members a $100 incentive bonus if they open a checking account with direct deposit which would start within 60 days. We understand all of the disclosure requirements for the $100 payment. The argument is, must we disclose in the ad that the $100 will be reported as interest to the IRS? We of course will be sending the member a 1099-INT and reporting it to the IRS, but are we required to disclose that?
Answer: 

If you are specifically paying for the establishment of the direct deposit and not the opening of the checking account, the $100 would be MISC income and not interest and subject to 1099MISC reporting and not 1099INT reporting.

First published on 05/12/2019

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