Update #1: The New Tip Deduction
The OBBBA introduces a new federal income tax deduction for “qualified tips.” This change directly affects municipalities that employ tipped workers in golf, banquet, and event operations.
What Has Changed
- Beginning in tax year 2025, employees in occupations that customarily and regularly receive tips may deduct up to $25,000 of qualified tips from their federal taxable income.
- The deduction phases out for individuals with modified adjusted gross income (MAGI) above $150,000 (or $300,000 for joint filers).
- The provision applies only through 2028, unless extended by Congress.
Recommended Next Steps for Municipal Employers
- Coordinate with Finance/Payroll departments to ensure all tips are currently being reported on employees' W-2 to ensure they can maximize their deduction amounts.
- Educate Supervisors & Staff about the deduction while clarifying that tips are still subject to FICA and must be reported.
- Review HR Policies & Handbooks to reflect the new rules.
- Monitor IRS Guidance on eligible occupations and reporting, expected by October 2025.
- Maintain Strong Recordkeeping to support employee claims and ensure compliance.
Summary
The OBBBA provides a new tax benefit by allowing employees to deduct up to $25,000 of qualified tips from federal income tax, but does not eliminate employer and employee responsibilities related to FICA, unemployment taxes, or wage/hour rules.
We will continue to provide updates as guidance is released, ensuring municipalities have the information they need to stay compliant.
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