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Important: New IRS Rules for 2026 Payroll and Tax Compliance for Tips

By Charles Peery, CPA | Business Tax Practice Leader

Significant IRS changes taking effect in 2026 will impact how businesses track, report, and substantiate employee tips. These new rules under Internal Revenue Code section 224 also affect how eligible employees may claim a federal income tax deduction for qualified tips. Taking steps now to understand and prepare for these requirements can help ensure compliance and avoid surprises when 2026 payroll reporting begins. Continue reading for detailed information.  

Key Points: 

  • Only “qualified tips” are deductible by employees under section 224. 
  • You must separately report cash tips and employee occupations on 2026 Forms W-2. 
  • Payroll and point-of-sale (POS) systems must be configured to capture and report tips in accordance with the new requirements. 
  • Not all tips are “qualified”; mandatory service charges and tips from certain businesses are excluded. 
  • Married employees must file jointly to claim the deduction, and the deduction is capped at $25,000 per return, regardless of filing status. 

Below, we outline the new requirements, explain how to distinguish between allowable and non-allowable tips, and highlight steps you can take now to prepare your payroll and reporting systems. Please contact us with any questions or if you would like assistance updating your payroll and recordkeeping processes.  

Detailed Guidance for 2026 Implementation

Understanding “Qualified Tips” under Section 224

Definition of Qualified Tips: 

  • Qualified tips are cash tips received by an individual in an occupation that customarily and regularly received tips on or before December 31, 2024, as listed in IRS guidance (e.g., wait staff, bartenders, bussers, etc.). 
  • “Cash tips” include tips paid in cash, by check, credit/debit card, gift card, or other cash-equivalent forms, and, for employees, tips received through tip-sharing arrangements. 
  • To be qualified, tips must be:  
    • Paid voluntarily by the customer, without compulsion or negotiation. 
    • Not a mandatory service charge or automatic gratuity unless the customer can freely modify or decline the amount. 
    • Not received in the course of a specified service trade or business (SSTB) as defined in section 199A(d)(2) (e.g., law, health, performing arts, etc.). 
    • Not received from an employer or payor in which the employee has an ownership interest or is employed by the payor of the tip. 

Non-allowable (Non-qualified) Tips: 

  • Mandatory service charges (e.g., automatic 18% gratuity for large parties). 
  • Tips received in the course of an SSTB. 
  • Tips paid by the employer or by a business in which the employee has an ownership interest. 
  • Tips received for illegal services or activities. 

Examples: 

  • A customer leaves a cash tip on the table after a meal: qualified tip. 
  • A customer pays a bill with an automatic 18% gratuity added, with no option to change or remove it: not a qualified tip. 
  • A bartender receives a tip from a customer at a restaurant (not an SSTB): qualified tip. 
  • A singer employed by a theater company (an SSTB) receives tips: not a qualified tip. 

 2026 Tip Reporting Requirements

Form W-2 Changes: 

  • For 2026, employers must separately report:  
    • The total amount of cash tips reported by the employee under section 6053(a). 
    • The employee’s occupation (as defined in the IRS list of occupations that customarily and regularly received tips). 
  • This information must be included in new or revised boxes on Form W-2. 

Payroll and POS System Setup: 

  • Configure payroll and POS systems to:  
    • Track and record all cash tips, including those paid by credit/debit card and through tip-sharing arrangements. 
    • Record the occupation of each tipped employee, using the IRS’s occupation codes. 
    • Distinguish between voluntary tips and mandatory service charges. 
    • Generate reports that separately account for qualified tips for each employee. 
  • Ensure that tip-outs (amounts distributed to support staff from pooled tips) are properly tracked and reported. 

Recordkeeping: 

  • Maintain contemporaneous records of all tips received and reported by employees. 
  • Retain documentation supporting the classification of tips as qualified or non-qualified. 
  • Keep records of employee occupations and any changes in roles. 

Steps to Ensure Compliance and Readiness

A. Review and Update Policies

  • Update employee handbooks and training materials to reflect the new tip reporting and deduction rules. 
  • Communicate the importance of accurate tip reporting to all staff.

B. System Configuration

  • Work with your payroll provider and POS vendor to ensure systems are updated for 2026 requirements. 
  • Test the system to confirm that it captures and reports tips and occupations as required. 

C. Documentation and Substantiation

  • Require employees to submit regular tip reports (e.g., daily, weekly, or monthly). 
  • Retain all tip reports, payroll records, and supporting documentation for at least three years. 

D. Monitor and Audit

  • Periodically review tip reporting for accuracy and completeness. 
  • Audit tip records to ensure that only qualified tips are being reported as such. 

E. Stay Informed

  • Monitor IRS guidance for any updates or clarifications on section 224 and tip reporting. 
  • Subscribe to IRS updates or consult with your tax advisor regularly. 

F. Employee Education

  • Hold training sessions for employees on the new rules. 
  • Provide examples of qualified and non-qualified tips. 
  • Explain the impact of the deduction cap and the joint filing requirement for married employees. 

G. Prepare for State Law Differences

  • Be aware that state tax treatment of tips may differ from federal rules; consult with your state tax advisor as needed.

Step for Employee Updates

A. Update form W-4

  • If you do not update your Form W-4, your federal income tax withholding will not reflect this new deduction. This means you may have more tax withheld from your paychecks than necessary, resulting in a larger refund at tax time but less take-home pay throughout the year. 
  • Estimate Your Qualified Tips for 2026: 
    • Qualified tips are voluntary cash or charged tips you receive from customers, including those received through tip-sharing arrangements. Mandatory service charges added to bills are not qualified tips. 
    • Only tips received in eligible occupations (as listed by the IRS) qualify. Most restaurant positions are included, but check the IRS list or ask HR if you are unsure. 
    • The maximum deduction is $25,000 per year, and the deduction phases out for individuals with modified adjusted gross income over $150,000 ($300,000 for joint filers). 
  • Complete the Deductions Worksheet: 
    • Use the Deductions Worksheet provided with Form W-4 (Step 4(b)) to estimate your total qualified tips for the year, up to $25,000. 
    • Enter your estimated qualified tips deduction on line 1a of the worksheet. Add any other deductions you expect to claim and follow the worksheet instructions to calculate the total amount to enter in Step 4(b) of Form W-4. 
  • Submit the Updated Form W-4: 
    • Complete a new 2026 Form W-4, entering your estimated deduction in Step 4(b). 
    • Submit the updated form to your employer as soon as possible to ensure your withholding is adjusted for the remainder of the year.

B. Proactive Tax Planning

  • Work with your tax advisor to ensure correct withholding. 
  • Update W-4 for any additional changes. 

With these changes approaching, now is the time to review your payroll processes and ensure your systems and documentation are ready for 2026. ATA can assist with system reviews, compliance planning, and employee guidance related to the new tip reporting and deduction rules. We encourage you to reach out with questions or to schedule time to discuss next steps. 

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General

New Overtime Deduction Rules for 2026

By Charles Peery, CPA | Business Tax Practice Leader

Background    

A new federal tax deduction could put meaningful dollars back in the pockets of workers who earn overtime. For tax years beginning after December 31, 2024, and before January 1, 2029, individuals (including employees and certain non-employees) may deduct up to $12,500 ($25,000 if married filing jointly) of “qualified overtime compensation” on their federal income tax returns. This deduction was created by section 225 of the Internal Revenue Code, as added by the One Big Beautiful Bill Act (OBBBA), and introduces new planning and reporting considerations for both taxpayers and employers.  

What Counts as “Qualified Overtime Compensation” 

  • Qualified overtime compensation is only the overtime premium required under federal law (the Fair Labor Standards Act). 
  • This includes pay for hours worked over 40 in a workweek at time-and-a-half. 
  • Only the “extra half” portion of time-and-a-half pay is deductible. 
  • Overtime that goes beyond federal requirement, such as double time, overtime required solely by state law, or pay under a collective bargaining agreement, does not qualify. 
  • Overtime pay that is effectively a tip does not qualify for the deduction. 

Deduction Limits and Income Phaseouts 

  • The maximum annual deduction is $12,500 per individual ($25,000 for married couples filing jointly). 
  • The deduction phases out as income increases: 
  • Reduced by $100 for every $1,000 of modified adjusted gross income (MAGI) above $150,000 ($300,000 for joint filers). 
  • MAGI includes certain foreign income exclusions added back to adjusted gross income. 

Eligibility Requirements 

To claim the deduction, taxpayers must include a valid Social Security number on their federal income tax return, and married individuals are required to file jointly in order to qualify. 

New Employer Reporting Requirements (Effective 2026) 

  • Employers must separately report qualified overtime compensation on Form W-2, box 19. 
  • This information must be provided to employees and the IRS by January 31 of the following year. 
  • For non-employees, qualified overtime compensation must be reported on Form 1099-MISC or Form 1099-NEC, as applicable. 
  • Payroll and reporting systems should be updated now to capture this information accurately for 2026. 

How the Deduction is Calculated 

  • Employees will generally use the amount reported in box 19 of Form W-2. 
  • If a separate total is not provided, employees may rely on pay stubs, payroll summaries, or other records to calculate the qualifying overtime premium. 
  • Non-employees should use earnings statements, invoices, or similar documentation to support the deduction. 

Practical Steps for Employers 

Employers should update payroll systems to separately track FLSA-mandated overtime premiums, communicate with employees about the new deduction and related reporting changes, and maintain detailed records of overtime hours, pay rates, and premiums paid. In addition, employers should prepare information return processes to ensure accurate W-2 and 1099 reporting for 2026 and consider whether employees may need to adjust withholding to reflect the anticipated deduction. 

Practical Steps for Employees 

Employees should regularly review their pay stubs to confirm overtime is properly calculated and classified, maintain copies of overtime pay records and any related employer communications, and verify that the amount reported in box 19 of Form W-2 matches their records.  

Married taxpayers must file jointly to qualify for the deduction, and all taxpayers should monitor their income levels to understand how phaseout thresholds may affect eligibility. 

Key Compliance Dates 

  • January 31, 2027 – Employers must furnish 2026 Forms W-2 and 1099s. 
  • April 15, 2027 – Deadline to file 2026 federal income tax returns and claim the deduction. 

Summary  

The new overtime deduction offers a significant tax benefit for eligible workers, but both employers and employees must ensure proper tracking, reporting, and substantiation of qualified overtime compensation. Employers should act now to update systems and procedures for 2026 compliance. 

Contact your ATA representative today for more information.

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General

Is it time for your business to start outsourcing?

By Brian Crafton, CPA | Outsourced Business Solutions Practice Leader

Outsourcing isn’t about giving up control; it’s about gaining capacity. As businesses grow, continuing to manage everything in-house can strain time, talent, and resources or expose the organization to unnecessary risk. The key is identifying which functions would improve efficiency, strengthen compliance, and allow leadership to focus on revenue-generating work.

Accounting and financial reporting are often among the first areas to benefit. With the right support, businesses can maintain accurate books, timely financial statements, and reliable close processes without the cost and complexity of expanding internal staff. Managed IT services can provide similar relief by reducing distractions caused by constantly changing technology while keeping systems secure, current, and dependable.

Outsourcing does require thoughtful planning. Selecting the right provider, protecting sensitive data, and maintaining clear communication are essential to building a successful long-term relationship. When approached strategically, outsourcing can become a meaningful advantage rather than a short-term fix.

Every business must determine when to outsource, which services make sense, and how to measure return on investment over time. Accounting and IT support are two of the most common functions businesses choose to outsource. If you’d like help evaluating whether these services are right for your organization, our team can provide guidance tailored to your needs. Contact ATA to schedule a consultation.

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Contribution Opportunities are Expanding in 2026

By Gabrielle Lorbiecki, CPA, CPC, QKC, QPA, QKA | Employee Benefit Plan Practice Leader

Great news for employees participating in your company’s 401(k) plan: contribution opportunities are expanding in 2026, giving workers even more room to save for the future. The standard 401(k) contribution limit will increase to $24,500 in 2026, up from $23,500 in 2025.

For team members age 50 and older, the catch‑up contribution limit will rise to $8,000, bringing their total possible 2026 contribution to $32,500.

Additionally, SECURE 2.0 introduced an enhanced “super catch‑up” contribution for employees ages 60–63, allowing them to contribute an extra $11,250 — potentially increasing their total annual 401(k) savings to $35,750 depending on plan adoption. Please note, availability of this enhanced catch-up contribution is subject to plan adoption and may not be offered by all employer plans.

Beginning in 2026, higher‑earning employees (those with prior‑year wages above $150,000, indexed for inflation) will be required to make all catch‑up and super catch‑up contributions on a Roth (after‑tax) basis. These contributions still allow tax‑free growth and tax‑free qualified withdrawals, helping employees build long‑term, flexible retirement income.

As these changes roll out, many employers and employees will have questions about plan design, eligibility, and how to maximize the new opportunities. ATA is here to help you navigate what’s ahead and ensure your plan is prepared for 2026.

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A New Year Checklist for Your Business: Preparing for a Strong 2026

The start of a new year is more than a fresh calendar, it’s an opportunity to reset, refocus, and strengthen your business for the months ahead. As 2026 begins, business owners should take time to evaluate operations, identify risks, and put the right resources in place to support sustainable growth. A thoughtful New Year checklist can help ensure nothing important gets overlooked.

1. Review financial performance and clean up your books.
Begin by reviewing last year’s financial statements. Are your books accurate, current, and telling a clear story? Timely reconciliations and reliable reporting are essential for informed decision-making. If in-house accounting has become stretched thin, outsourced accounting services can help streamline monthly close processes, improve reporting accuracy, and free your team to focus on higher-value work.

2. Plan proactively for taxes.
Tax planning shouldn’t start in April. Early in the year is the ideal time to review tax strategies, entity structure, and upcoming compliance requirements. With tax laws continuing to evolve, proactive planning can uncover opportunities to reduce liability, improve cash flow, and avoid surprises. Aligning tax planning with overall business goals is a critical step for 2026 success.

3. Evaluate technology and cybersecurity readiness.
Technology is no longer just a support function; it’s a business driver. Review whether your systems are secure, updated, and aligned with how your team actually works. Managed IT services can help ensure your network is protected, your data is backed up, and your technology supports growth rather than creating risk or downtime.

4. Assess internal processes and capacity.
As businesses grow, processes that once worked can become inefficient or risky. Take stock of who is handling key functions like accounting, payroll, HR, and IT. If critical responsibilities rest with one person or distract leadership from strategic priorities, outsourcing may provide scalability, consistency, and peace of mind.

5. Revisit growth and advisory needs.
A new year is the right time to clarify goals; think about expansion, succession planning, acquisitions, or operational improvements. Advisory support can help translate those goals into actionable plans, backed by data and practical guidance.

At ATA, businesses have access to integrated resources across tax, outsourced accounting, managed IT, advisory, and more, which are all designed to support smarter decisions and long-term success. Starting 2026 with the right checklist and the right partners can help position your business for a productive, confident year ahead. Schedule a consultation with our team.

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Secure, Scale, Save – Your 2026 Playbook

A strong 2026 starts with a strong foundation. This new article explores what it means to “secure” your organization across tax, HR, and IT and how the right steps today can reduce risk and protect the business tomorrow.

Tax: Securing Financial Integrity and Compliance Posture

Key Risks
Many companies approach 2026 with books and entity structures that cannot withstand regulatory scrutiny. Inaccurate or commingled financials block effective tax planning. QBI eligibility is frequently missed when income drifts outside optimal ranges. S corporation owners often lack reasonable compensation analyses, increasing audit exposure.

When a business grows but its entity structure does not, inefficiencies accumulate quietly and compound over time.

What Organizations Must Do
A secure tax environment begins with clean, separate books for each legal entity. Leaders should conduct annual reviews of entity structure to ensure alignment with tax policy changes and future planning goals. Modeling QBI thresholds helps keep income positioned to maximize deductions. Conducting reasonable compensation analyses reduces audit risk.

PTET elections and other strategic opportunities should be used intentionally and only when financial data is accurate and well-maintained.

HR: Securing People, Data, and Compliance Infrastructure

Key Risks
HR functions continue to manage more sensitive data than most leaders realize Social Security numbers, banking details, dependent records, and payroll histories often stored in spreadsheets, email attachments, or shared drives lacking basic protection. At the same time, compliance exposure grows through I-9 errors, misclassified workers, and inconsistent multistate payroll practices.

Poorly structured onboarding and o­ffboarding processes extend system access long after employment changes, creating preventable security gaps.

What Organizations Must Do
Strengthening HR security requires discipline and modernization. Sensitive information must be moved into secure systems, eliminating manual or ad-hoc data storage. Standardized onboarding and offboarding procedures ensure system access is granted and removed consistently. Annual compliance audits should validate worker classification, I-9 accuracy, and state payroll rules.

Finally, HR and IT must align, reinforcing training on cybersecurity awareness, data protection, and responsible use of emerging AI tools.

IT: Securing Digital Infrastructure and Cyber Defenses

Key Risks
AI-enabled cyber threats are accelerating in frequency and sophistication. Yet many organizations still lack baseline controls such as multi-factor authentication, centralized device management, and automated patching. Backups exist but are rarely tested, reducing confidence in recovery.

Slow detection times and inconsistent user-access management, especially during turnover, remain major sources of vulnerability.

What Organizations Must Do
A secure technology environment requires enterprise-grade standards applied consistently. Multi-factor authentication should be mandatory across all systems. Device management must be centralized to enforce updates, patches, and secure configurations. Backups should be automated, encrypted, and routinely tested.

Cybersecurity awareness training and phishing simulations reduce human-driven risk. Organizations lacking internal expertise should consider 24/7 monitoring to ensure real-time threat detection and rapid response.

Conclusion

Security is the foundation of sustainable growth in 2026. When HR protects sensitive data, Tax ensures financial integrity, and IT fortifies digital defenses, businesses reduce risk dramatically and unlock the strategic clarity needed to scale confidently.

Securing these core areas is not optional, it is the prerequisite for everything that comes next.

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Top 5 Matters Keeping Business Owners Up at Night and How ATA Can Help 

 

By Rick Schreiber, CPA,CVGA, CGMA, M&AP | Advisory Practice Leader 

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Running a business today is more complex than ever. From economic uncertainty to talent shortages, business owners are navigating a minefield of challenges. In our recent client survey, many of you shared that you weren’t aware of all the ways ATA can support your business, and that you’re looking for more proactive advice. This article is designed to highlight some of the most common challenges we hear, and how ATA and its growing advisory services is helping clients navigate them. 

  1. Financial Stress & Cash Flow Uncertainty

The Worry:
Business owners are constantly juggling cash flow, trying to make payroll, cover rising costs, and still turn a profit. Inflation, interest rate hikes, and supply chain disruptions have only added to the pressure. Many are unsure whether they’re pricing correctly, overstaffed, or missing opportunities to improve margins. The stress of not knowing if they’ll have enough cash next month or next quarter can be paralyzing. Without clear financial visibility, even strong businesses can feel like they’re flying blind. 

Our Suggested Solutions: 

  • Fractional CFO services to improve forecasting and cash flow discipline 
  • Cost and margin optimization to uncover savings and improve profitability 
  • Strategic planning to diversify revenue and reduce financial risk 
  1. Growing Revenue in a Crowded Market

The Worry:
Owners are feeling squeezed. Competitors are slashing prices, customers are more demanding, and digital disruption is changing how people buy. Many businesses are stuck in a cycle of flat growth, unsure how to break through. They may be relying too heavily on a few key clients or outdated sales tactics. The fear of stagnation or worse, decline is real. Without a clear growth strategy, even the best-run companies can lose ground.  

Our Suggested Solutions: 

  • Growth advisory to identify new markets, products, or pricing strategies 
  • Digital advisory to enhance online presence and customer experience 
  • Sales process and CRM optimization to improve conversion and retention
  1. Attracting and Retaining Talent

 The Worry:
The labor market has shifted and many business owners are struggling to keep up. Younger workers want more than a paycheck; they want purpose, flexibility, and growth. Meanwhile, experienced employees are being poached by competitors offering better benefits or remote options. Owners worry about losing institutional knowledge, training new hires, and maintaining morale. They know that without the right people, growth stalls, and culture suffers.  

Our Suggested Solutions: 

  • HR advisory to improve recruitment, onboarding, and retention 
  • Compensation, benefits, and retirement plan design to attract and retain top talent 
  • Culture and engagement assessments to strengthen morale and loyalty
  1. Regulatory Complexity & Compliance Risk

 The Worry:
From shifting tax codes to evolving labor laws and cybersecurity regulations, the compliance landscape is a moving target. Business owners worry about missing something critical, like a new reporting requirement or a data privacy rule that could lead to fines, audits, or reputational damage. Many don’t have the time or expertise to keep up, and they fear that one misstep could undo years of hard work. 

Our Suggested Solutions: 

  • Regulatory compliance reviews and risk assessments 
  • Internal audit and controls advisory 
  • Tax advisory to navigate evolving federal and state rules 
  1. Technology Disruption & Cybersecurity Threats

The Worry:
Technology is advancing faster than most businesses can adapt. Owners know they need to modernize but fear the cost, complexity, and potential for cyberattacks. They’re unsure which tools are worth the investment, how to train their teams, or how to protect sensitive data. The fear of a ransomware attack or system failure keeps many up at night. And without a clear digital strategy, they risk falling behind competitors who are already embracing automation and AI. 

Our Suggested Solutions: 

  • Digital transformation and automation advisory tailored to small and mid-sized businesses 
  • Cybersecurity readiness assessments and employee training 
  • Strategic tech planning to reduce complexity and future-proof operations

Closing Thought 

At ATA, our goal isn’t just to solve problems, it’s to be the partner who helps you seize opportunities, build resilience, and move forward with confidence, so you can sleep better at night. Let’s start the conversation today. 

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General

Why a 401(k) is Better Than a SIMPLE IRA

By Gabrielle Lorbiecki, CPA, CPC, QKC, QPA, QKA | Employee Benefit Plan Practice Leader 

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When business owners evaluate retirement plan options, two common choices are the 401(k) and the SIMPLE IRA (Savings Incentive Match Plan for Employees). While the SIMPLE IRA is often appealing for very small businesses due to its simplicity, the 401(k) generally provides more flexibility, higher contribution limits, and stronger long-term benefits for both employers and employees.

Below, we’ll break down why a 401(k) is typically the superior choice, including contribution maximums, employer flexibility, and important deadlines for converting a SIMPLE IRA into a 401(k).

Key Advantages of a 401(k) Over a SIMPLE IRA

  1. Higher Contribution Limits

A primary advantage of a 401(k) is the much higher contribution ceiling. Employees can defer significantly more of their salary, and employers can make discretionary contributions up to the annual IRS limits.

Plan Type (2025) Employee Deferral Limit Catch-Up (Age 50+) Employer Contribution  
401(k) $23,500 $7,500 Up to 25% of current IRS compensation limit
SIMPLE IRA $16,500 $3,500 Mandatory match (3%) or 2% nonelective
  1. Plan Design Options

401(k) plans can include:

  • Loans to participants.
  • Safe harbor provisions to simplify compliance.
  • Profit-sharing contributions that can be allocated strategically to owners or key employees.

SIMPLE IRAs, by design, lack these customization options. In addition, 401(k) plans may be designed to meet your company’s specific goals and can be updated as your business grows and changes over time.

  1. Better Long-Term Retirement Accumulation

Because of the higher contribution limits and employer discretion, 401(k) participants can build wealth faster than those in SIMPLE IRAs. This makes the 401(k) particularly advantageous for business owners seeking to maximize their own retirement savings.

Deadlines to Convert from a SIMPLE IRA to a 401(k)

If your business already has a SIMPLE IRA and you’d like to switch to a 401(k) effective January 1, 2026, employers must notify employees of any changes by November 2, 2025.

Schedule a Consultation

While a SIMPLE IRA may be suitable for very small or new businesses, the 401(k) offers greater savings potential, plan flexibility, and strategic advantages for business owners and employees alike. With higher contribution limits and advanced plan features designed to meet your company’s goals, a 401(k) is often the better long-term choice.

For businesses currently using a SIMPLE IRA, careful planning around the November 2 conversion deadline ensures a smooth transition to the more powerful 401(k) platform.

Ready to explore whether a 401(k) is right for your business? Contact our team today to review your retirement plan options and map out the best strategy for your company’s future.

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General

New Tip and Overtime Reporting Rules for Employers under OBBBA

What Employers Need to Know for Tax Years 2025 through 2028 

By Charles Peery, CPA | Business Tax Practice Leader

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The One Big Beautiful Bill Act (OBBBA) introduces new federal reporting rules for businesses that employ tipped workers or overtime eligible staff. Effective for tax years 2025 through 2028, these changes emphasize wage transparency without drastically altering enforcement or eligibility rules. Instead, employers are expected to meet new documentation standards, especially for tip income and overtime premium pay. This article outlines the key provisions and best practices to help your business stay compliant and prepared. 

 

  1. Annual Tip Reporting Requirements

The OBBBA enhances annual wage reporting required for tipped employees but does not mandate real time or per pay period submissions. 

Key changes include: 

  • Employers must report the total qualified tips received by each employee on Form W-2, along with their qualifying occupation. 
  • Qualified tip income includes cash tips, credit card tips, and pooled tips that are voluntary and customary. 
  • Mandatory gratuities and service charges are not included. 
  • The existing rule that employees must report all tips to employers by the tenth of the following month remains in place. 
  • No changes were made to existing federal rules on tip pooling. 
  • A new deduction allows employees to exclude up to 25,000 dollars of qualified tip income annually. The deduction begins to phaseout once modified adjusted gross income exceeds 150,000 dollars for single filers and 300,000 dollars for joint filers. 
  • Workers may claim the deduction regardless of whether they itemize deductions or claim the standard deduction.  

Strategic takeaway: Ensure your payroll system supports detailed end of year tip tracking and that your employees understand their responsibilities. 

  1. Best Practices for Verifying Tip Income
  • Keep detailed records: Encourage employees to log tips daily and keep employer copies of all reports for at least four years after the tax deadline. 
  • Participate in IRS tip agreements: Consider agreements such as TRDA, TRAC, or GITCA for added compliance support. 
  • Train employees: Provide training on tip policies and include written guidance in your employee handbook. 
  • Use technology: Electronic tracking tools can help automate reporting and provide tax summaries for employees. 

 

  1. Overtime Reporting for a New Deduction

Although the OBBBA does not change who qualifies for overtime under federal law, it does introduce a new deduction for the premium portion of qualified overtime pay. 

Key provisions include: 

  • Only the additional half time pay required by federal law qualifies. 
  • State mandated or contract-based overtime does not qualify. 
  • Employers must report qualified overtime premium pay separately on Form W-2. 
  • Employees can deduct up to $12,500 individually or $25,000 jointly. The deduction phases out for single filers with MAGI over $150,000 and joint filers with MAGI over $300,000. 
  • The overtime deduction is available to both itemizers and nonitemizers.   
  • No additional enforcement, attestation, or documentation mandates have been introduced. 

Strategic takeaway: Your payroll system must be able to isolate and report the qualifying overtime premium amounts accurately. 

  1. Best Practices for Overtime Pay Documentation
  • Implement reliable time tracking: Use time clocks or software that accurately captures hours, breaks, and overtime. 
  • Separate overtime premium pay: Payroll systems should be configured to track the extra half time pay separately for reporting. 
  • Retain supporting documents: Maintain records of timecards, payroll reports, and communication regarding compliance. Assign responsibilities clearly between departments to improve oversight. 
  1. IRS Compliance and Internal Controls

Participating in IRS tip programs like TRDA, TRAC, or GITCA can reduce audit risk and help demonstrate good faith compliance. Employers in these programs are required to submit annual reports on tip income and hours worked. 

Strategic takeaway: Establish strong internal controls and update your policies and procedures to align with OBBBA standards. 

Schedule a Consultation 

Now is the time to assess your payroll systems and reporting practices. Schedule a consultation with your ATA advisor to prepare for the 2025 reporting season and reduce the risk of penalties. Our team can help you stay compliant and confident under the new law. 

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General

Why a Mid-Year Check-In with Your Accountant Matters

By Mark Puckett , CPA | Tax Principal 

The halfway point of the year isn’t just a time to reflect, it’s a smart opportunity to reset. A mid-year check-in with your accountant helps you evaluate progress, respond to changes, and strategically plan for what’s ahead. Whether you’re an individual, a business owner, or a nonprofit leader, this proactive step can prevent surprises and position you for a strong year-end finish. 

Get Ahead of Potential Issues 

Waiting until year-end to discover financial gaps or tax surprises can leave you with limited options. Meeting with your accountant now gives you time to address concerns while there’s still room to act. Common topics include tax estimates, income or deduction changes, cash flow shifts, and budget variances. Catching these early allows for more flexibility and peace of mind heading into Q4. 

Make the Most of Tax Strategies 

Tax laws continue to evolve, and the earlier you plan, the better your chances of maximizing savings. Your accountant  can help you assess the potential impact of new tax law changes on your specific situation. By working together to discuss your ongoing plans, you have a much better opportunity to take advantage of the tax laws. With half the year behind you, projections based on real numbers make your decisions smarter and more impactful. 

Check In on Business Health 

For business owners, a mid-year financial review is essential. Your accountant can analyze your year-to-date numbers, compare them to forecasts, and evaluate performance indicators such as margins, expenses, and cash flow. These insights can guide decisions around pricing, hiring, capital purchases, and goal setting for the remainder of the year. 

Stay Aligned and Compliant 

This check-in also ensures you’re staying on top of compliance, whether it’s sales tax filings, payroll reports, or estimated payments. Nonprofits can use this time to review grant tracking, audit readiness, and mission alignment. Individuals may want to discuss life events like a marriage, new child, or property purchase that could affect their tax picture.  

Be Proactive 

A mid-year conversation with your accountant is more than a check-in, it’s a strategic move to stay informed, adaptable, and confident. Don’t wait for year-end stress. Reach out to your ATA advisor today and make sure you’re on track to finish the year strong.