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Understanding Tax Reporting and Promos

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Question: 
I recently joined a bank - just in time to jump into the tax reporting errors! In 2007 we offered a wide variety of promotional campaigns. In some campaigns, we offered bonus dollars (more than $20) for a new account opening. We also offered a bonus gift for closing on a loan with us (value over $25). We gave away gift cards (again, more than $20 value) for a new account relationship and finally, had a gift book where customers could choose a gift based on the number of times they used their debit card. The people that received these bonuses included businesses, consumers, lending and deposit relationships.It is my understanding that if the value of the premium - cash or physical item - is greater than $20, a 1099-INT must be created for the value of the item. However, there are others who believe that only cash items or gift cards fall under the 1099-INT rule and physical items fall under 1099-MISC reporting. If under 1099-Misc, it is understood that the value must be greater than $600 and does not apply to businesses.What is the proper way to report the following - assuming value over $20, and what special rules would apply if the recipient was a business?<ol><li>Bonus dollars added to deposits<li>Gift cards given for referring a friend <Li>Gift cards given for opening an account<Li>Gift item given for closing a loan<Li>Gift item given for debit card usage.</ol>
Answer: 
  1. If the bonus dollars are a reward for opening an account, it's treated as 1099-INT interest.1a. If the bonus dollars are actually for a side-service (for example, signing up for direct deposit), it's other income reportable under the 1099-MISC rules (assuming the annual $600 trigger is reached)
  2. 1099-MISC rules
  3. Same as #1. The value of the gift card is considered interest.
  4. 1099-MISC rules
  5. 1099-MISC rules.

For a business, you look to the form of ownership. If it's a sole proprietorship, look to the rules above. If it's a corporation or other business entity, the 1099 rules won't apply, but if item 1 or 3 in your list for a checking account, you'd better have a Regulation Q section 217.101(b) exception you can point to, or you'll be in violation of the rule against paying interest on demand deposits.

First published on BankersOnline.com 3/03/08

First published on 03/03/2008

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