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Reconciliation bill includes notable compensation and benefits changes


Related topics

Two central changes made by the law include limited deductions for both tips and overtime for tax years 2025 through 2028.


In brief

  • How will new deductions for tips and overtime affect employee reporting and employer compliance?
  • What are the implications of the updated executive compensation and employee benefits rules?
  • Which credits and exclusions can employers leverage under the revised law?

President Trump signed tax reconciliation legislation (the Law) on July 4, 2025, that contained several provisions affecting compensation and benefits, including individual deductions for tips and overtime, and the tax treatment of various employee benefits. The Law creates individual deductions for tips and overtime, which are premised on new employer reporting, and makes changes to existing provisions, including the deduction disallowance for employer-provided meals, the executive compensation excise tax for tax-exempt organizations and the executive compensation deduction for publicly held corporations, among others.

The Law creates a new IRC Section 224, which allows a federal income tax deduction for qualified tips of up to $25,000 for both employees and independent contractors for tax years 2025 through 2028. The deduction is available to itemizers and non-itemizers and begins to phase out for adjusted gross income (AGI) over $150,000 ($300,000 joint).

 

The Law also creates new IRC Section 225, which allows a federal income tax deduction for qualified overtime compensation of up to $12,500 ($25,000 in joint) that is reported on Form W-2 for tax years 2025 through 2028. The deduction is available to itemizers and non-itemizers and begins to phase out for AGI over $150,000 ($300,000 joint).

 

Also included in the Law is a statutory aggregation rule to IRC Section 162(m), which limits the deduction for compensation in excess of $1 million paid to covered employees of a publicly held corporation. When a specified covered employee is paid by different members of a controlled group, the amounts will be combined for purposes of the $1 million limit based on rules under IRC Section 414. The allowable deduction will be divided among the members based on their pro-rata share of the total compensation paid to the covered employee.

Summary

Several changes were made to the rules impacting compensation and benefits which will require employers to closely examine their reporting and tracking systems.

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