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The hidden tax cost of bank incentive rewards


Banks often provide awards to lure new customers or to strengthen customer loyalty. Awards can take the form of a simple gift (cash or non-cash) or can be more complex, such as a sweepstakes involving some element of chance, or a reward points program.

If you have received an award from a bank, the IRS, always ready to claim the government’s share, may come knocking on your door. Taxation is dependent on how you receive the awards, what the award is, and its value. In certain situations, banks are required to, and may send a Form 1099, which reports the award value to the IRS and the award recipient. Here are some different award scenarios and corresponding actions to take.

Awards for Opening an Account
Awards for opening accounts are generally considered interest income and are taxable to the account holder. If an award is paid in cash, the amount of interest income is the amount of cash paid. However, an award may also be non-cash, such as a gift card or a specified item (e.g., an item of merchandise from a rewards brochure). Gift cards are normally valued at the amount of the gift on the card and merchandise at retail value. Once the value of all rewards are tallied, the value should be added to any other interest earned on the account. If the total is at least $10, the IRS requires you to file a Form 1099-INT.

Cash awards are generally easier to administer as the award can be deposited to the customer’s account and credited as interest. In-kind awards often present additional complexity when filing Forms 1099. These awards are often purchased in bulk, and given to customers when they open an account. Therefore, you don’t include the value in the customer account and you can only capture it in the 1099 reporting processes using manual intervention. To ensure these values are captured, you should develop procedures to address any manual processes.

Miscellaneous Awards Programs
Awards provided for something other than the use of money (e.g., opening an account) may also be taxable. For example: amounts provided under a birthday gift program could be taxable. Assume, under a birthday gift program, all customers under the age of 19 receive a $5 gift on their birthday. As the amounts do not appear to be for the use of money (no new account necessary and no specified account balance necessary), these payments would NOT be included on Form 1099-INT.

However, the government still wants their portion. Oftentimes, amounts under these types of programs are very low and do not require tax reporting. If reporting is required, amounts would be included on Form 1099-MISC rather than Form 1099-INT.

You need to consider these payments under the 1099-MISC reporting rules. These rules, different than the 1099-INT rules, only require reporting when the aggregate payments during the year exceed $600. Therefore, no IRS reporting would be required under this program unless payments under this program and any other program which would require a 1099-MISC, exceed $600.

Account Opening Sweepstakes
Occasionally, an incentive program may take the form of a sweepstakes or similar give-away. Winners are chosen randomly, from a pool consisting of customers opening a new checking account during a specified time period and, perhaps, non-customers if a no-purchase required entry option is available. As these prizes are limited and determined by luck (not by skill or by virtue of having an account, other than it qualified them for entry) this is more properly reported as a gambling winning. Gambling winnings are reported on Form W-2G (when in excess of $600).

IRS rules require mandatory withholding for certain gambling prizes. IRS rules also require income tax withholding for proceeds of more than $5,000. The IRS provided an example in their rules that states when no wager is placed, withholding is not required. The example concerns those entered into the sweepstakes simply by virtue of purchasing a magazine subscription for which they paid the regular subscription price. As new checking account customers generally are not paying additional amounts or receiving different terms than the regular terms an account holder receives, they are not considered to have made a wager. Therefore, we believe withholding is not required because there is a withholding exception if no wager is placed.

Reward Points Programs
Benefits from reward points programs are more complex and may not be subject to tax and reporting, depending on the provisions of the program.

The IRS has ruled that a program that is not transferable and is not convertible into cash or cash equivalents should not create gross income to the enrollees. Therefore, amounts earned and collected under a similar program would not be subject to information reporting rules, and not included on Form 1099-MISC.

Furthermore, in some circumstances cash-back options do not create gross income because the cash-back options are treated as a discount on the purchase or a rebate. In short, you have actually paid less for your merchandise because of the discount/rebate provided by the credit card.

However, if there is an award or cash provided simply for signing up for the card (no purchase necessary) the benefit may be taxable and includible on Form 1099-MISC, if the minimum threshold of $600 is satisfied.

Incentive programs to acquire and retain customers may result in taxable income to the customer. Additionally, information reporting may be required if the aggregate amount of all benefits provided exceeds certain thresholds.

We recommend banks review their procedure with regard to incentive programs to ensure proper tax reporting. We also suggest developing a customer-facing communication plan when incentives involve a significant benefit, so that customers are informed of their obligations and not surprised by hidden and unexpected tax costs. We are happy to assist in this area.