Given that Alex is a U.S. citizen residing in Bermuda and Vincente is a U.S. income tax nonresident alien, the interest income received by Vincente from Alex may be considered as U.S.-source income and thus subject to withholding tax unless an exception applies. However, if there is a tax treaty between the United States and Bermuda that provides for a reduced withholding tax rate on interest income, then Vincente may be eligible for a reduced withholding tax rate on the interest income received from Alex