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$100 Incentive Bonus-Disclose IRS Report on Ad?

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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?

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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