One Big Beautiful Bill Act

In Notice 2025-62, released on November 5, the IRS provided temporary relief to employers and payors for failing to comply with certain reporting requirements added to the Internal Revenue Code by the One, Big, Beautiful Bill Act (OBBBA) in conjunction with sections 224 and 225 of the Internal Revenue Code (see prior coverage).  Subsequently, in Notice 2025-69, the IRS provided guidance to employees and payees as a result of the relief provided by the earlier notice to employers and payors.  Under sections 224 and 225 and subject to certain limitations, employees and payees are entitled to deductions for qualified tips and qualified overtime compensation in the amount employers and payors provide on statements furnished to employees and payees.  As part of that regime, the Act added new information reporting requirements that require employers and payors to report qualified tips and qualified overtime compensation to the IRS.  It also requires third party settlement organizations (TPSO) whose gross payments exceed a certain threshold to report qualified tip information to the IRS.Continue Reading IRS Notices Provides Relief from Qualified Tips and Qualified Overtime Reporting Requirements and Guidance for Employees and Payees

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

Signed into law by President Trump on July 4, 2025, the One Big Beautiful Bill Act (“OBBBA”) (H.R. 1) adds section 6050AA to the Internal Revenue Code to adopt new information reporting requirement requiring businesses receiving interest on car loans from individuals to report specified information to the IRS (presumably on a new form in the 1098 series) and to provide a written statement to the payers.  The requirement is similar to those under section 6050H for businesses receiving payments of mortgage interest.  The requirement was adopted in conjunction with a new tax deduction for up to $10,000 in interest paid on loans used for the purchase of passenger vehicles assembled in the United States.  (The deduction is subject to a phaseout for individuals with adjusted gross incomes above $100,000 ($200,000 for married filing jointly.)Continue Reading Auto Loan Interest Deduction Comes with New Information Reporting Requirement for Lenders

The House today passed the Senate-passed version of the One Big Beautiful Bill Act (H.R. 1) (“OBBBA”), which includes a number of major tax provisions, including a number of provisions that would affect withholding and information reporting obligations (see prior coverage here, here, here, here, here, and here—note that earlier coverage of some other provisions in the original House bill were dropped or modified from the legislation that was ultimately enacted).

One provision that was in the original House-proposed legislation but then removed before it passed the House found its way back into the final legislation that ultimately passed the House and Senate. Section 112205 of OBBBA includes enforcement provisions related to COVID-Related Employee Retention Credits. That credit was originally enacted as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act in 2020 and then extended and expanded in 2021. The credit, which was modeled on a credit previously used for physical disasters such as hurricanes and wildfires, was intended to cover a portion of employer’s payroll costs to encourage them to keep employees on payroll and was similar to programs enacted in other countries during the COVID-19 pandemic.

Unfortunately, the credit became mired in IRS delays as the IRS struggled to process the influx of claims amid staffing shortages of its own. The IRS released guidance in the form of FAQs, which this blogged detailed, and then later in more formal notices, which became more restrictive over time. (See our earlier three-part series on IRS guidance: here, here, and here.) In the face of this guidance, a cottage industry began advising employers on the credit, some of whom took increasingly aggressive positions in the view of the IRS—and in the views of some tax professionals. Section 112205 of OBBBA is a response to those perceived abuses.

OBBBA (1) retroactively suspends some pending claims for the employee retention credit; (2) extends the limitation period on assessments for some employee retention credit claims; (3) extends the penalty on excess refunds to employment taxes; and (4) adds a new of enforcement provisions targeting “COVID-ERTC Promoters.”Continue Reading Reconciliation Bill Affects Pending ERC Claims; Cracks Down on ERC Promoters