It is not a regular one-time promotion. It is just a requirement to use the credit card, with a minimum spend requirement every month. I have done this for more than one year w/o any issues. I have also not found anything in the terms that would violate the Terms (it is a very small and special bank).
I find this hard to understand why this would be "structuring" as I am not trying to avoid any reporting. Is is the opposite, PayPal will report something that, I believe, should not be reported.
Per the new IRS regulation, I understand that personal transfers should not be reported by PayPal on a 1099-K, no matter the source of the funds, via credit card or bank account. This is true whether between spouses, friends or other (See (b)):
SEC. 9674. MODIFICATION OF EXCEPTIONS FOR REPORTING OF THIRD PARTY NETWORK TRANSACTIONS.
(a) In General.—Section 6050W(e) of the Internal Revenue Code of 1986 is amended to read as follows:
“(e) De Minimis Exception For Third Party Settlement Organizations.—A third party settlement organization shall not be required to report any information under subsection (a) with respect to third party network transactions of any participating payee if the amount which would otherwise be reported under subsection (a)(2) with respect to such transactions does not exceed $600.”.
(b) Clarification That Reporting Is Not Required On Transactions Which Are Not For Goods Or Services.—Section 6050W(c)(3) of such Code is amended by inserting “described in subsection (d)(3)(A)(iii)” after “any transaction”.
