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Christina Danberg Bubel

Christina Danberg Bubel is an associate in the firm’s Washington, DC office, where she is a member of the Tax Practice Group. Christina also maintains an active pro bono practice.

Christina earned her J.D. from the Georgetown University Law Center, where she mentored law students in legal writing as part of the Law Fellow Program.

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On April 10, the IRS released final regulations to implement and provide guidance regarding new Section 224, enacted as part of the One Big Beautiful Bill Act (P.L. 119-21).  Section 224 allows single filers who earn up to $150,000 annually or married couples who earn up to $300,000, to deduct up to $25,000 in qualified tips received during the tax year in an occupation that customarily and regularly received tips on or before December 31, 2024.  (See prior coverage.)  No deduction is allowed under section 224 for any year beginning after December 31, 2028.  The final regulations made several, generally minor, changes to the proposed regulations based on feedback the IRS received during the comment process.  The final regulations list 71 job titles that “customarily and regularly receive[] tips,” and so would qualify for the deduction.  This list adds three additional job titles to the proposed regulation’s list of 68: floral designers, visual artists, and gas pump attendants.

The final regulations also provide additional guidance on the requirement that tips be reported, further clarification on the definition of cash tips, specific guidance for certain eligible and ineligible occupations and activities, continued relief from the specified service trade or business exclusion, and new anti-abuse rules.

Continue Reading IRS Issues Final Regulations on Tipped Income Deduction

On September 19, 2025, the IRS published proposed regulations to implement and provide guidance regarding new Section 224, enacted as part of the One Big Beautiful Bill Act (P.L. 119-21).  The proposed regulations define qualifying payment methods, jobs that customarily receive tips, and exclusions from the deduction.

Section 224 would allow single filers who earn up to $150,000 annually or married couples who earn up to $300,000, to deduct up to $25,000 in qualified tips received during the tax year in an occupation that customarily and regularly received tips on or before December 31, 2024.  The deduction phases out for taxpayers with modified adjusted gross income over $150,000, and over $300,000 for joint filers.  The proposed regulations clarify that the maximum deduction is reduced (but now below zero) by $100 for each $1,000 by which the taxpayer’s modified adjusted gross income exceeds the $150,000 (or $300,000) limit.  To be deductible, tips must be included on reporting statements, such as the Form W-2 or Form 1099.  No deduction is allowed under section 224 for any year beginning after December 31, 2028.

Continue Reading No Tax on “Qualified” Tips:  IRS Issues Proposed Regulations on Tipped Income Deduction

Early this morning, the House of Representatives passed a reconciliation bill that would enact significant tax provisions and spending cuts.  The House Bill now heads to the Senate, where changes are likely before passage.  This article is one of a series of articles discussing various proposals in the legislation that touch on tax withholding, reporting, and fringe benefits.

The House bill would expand the application of tax on excess compensation for tax-exempt organizations by redefining a covered employee as one who receives income in excess of $1 million annually. 

Continue Reading House Reconciliation Bill Would Expand the Employees Covered by Excess Remuneration Rules for Nonprofit Organizations

Early this morning, the House of Representatives passed a reconciliation bill that would enact significant tax provisions and spending cuts.  The House Bill (H.R. 1) now heads to the Senate, where changes are likely before passage.  This article is one of a series of articles discussing various proposals in the legislation that touch on tax withholding, reporting, and fringe benefits.

The House Bill expands two credits designed to help employers cover the cost of employer-provided child care and paid family and medical leave.

Continue Reading House Reconciliation Bill Would Extend Tax Credits for Family and Medical Leave and Child Care

On February 21, 2025, the IRS issued Notice 2025-15, which provides guidance regarding the alternative manner of furnishing certain health insurance coverage statements to individuals under I.R.C. sections 6055(c)(3) and 6056(c)(3).  President Biden signed the Paperwork Burden Reduction Act (H.R. 3797) in December 2024, eliminating the requirement to automatically…

Continue Reading IRS Issues Guidance Easing ACA Reporting Requirements

On January 16, 2025, the IRS published proposed regulations to implement and provide guidance regarding amendments made to section 162(m) as part of the American Rescue Plan Act of 2021 (ARPA).  These proposed regulations expand the compensation deduction limitation for publicly held corporations under I.R.C. section 162(m), beginning in 2027.…

Continue Reading IRS Issues Proposed Regulations to Expand Limitation on Compensation Deduction for Publicly Held Corporations