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Tax Strategy: IRS issues guidance on OBBBA deductions and related payroll changes

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Since the enactment of H.R. 1, the One Big Beautiful Bill Act, the Internal Revenue Service has announced that it will not be updating 2025 tax forms such as the W-2 and 1099s to reflect OBBBA changes impacting 2025 tax returns. 

Instead, it intends to provide guidance on how to implement the OBBBA with the existing forms. 2025 guidance is needed on how to reflect tips that qualify for the tip deduction on the 2025 tax return. Guidance is also needed on how to reflect qualifying overtime to qualify for the overtime deduction. These may require alteration of payroll practices. Guidance may also be needed on Trump Accounts and the possibility that employers may want to make contributions to the accounts of employees’ children.

The IRS has released the draft version of a new Form 1040 Schedule 1-A, which discusses the calculation of the new below-the-line deductions for tips, overtime, car loan interest, and seniors. It has also released a draft Form 1040 for 2025. The IRS also released proposed regulations with respect to the tips deduction. Although the IRS is not planning to revise the 2025 version of Form W-2, it has issued a draft version of the 2026 Form W-2.

Schedule 1-A

A new draft Schedule 1-A is to be utilized in the calculation of each of the four new below-the-line deductions on the schedule. Part I of draft Schedule 1-A is for insertion of modified adjusted gross income, which will be utilized in calculating the impact of the phase-outs of the deductions.

Tip deduction

Part II of the schedule is for the calculation of the qualified tip income deduction. Qualified tip income for an employee is to be reported on Form W-2, Box 7, only if income reported on Form W-2 Box 5 is $176,000 or less. Qualified tips may also be reported on Form 4137, Line 1(c) for Social Security and Medicare tax on unreported tip income. 

It does not appear that draft Form 4137 has yet been updated to reflect this information on Line 1(c). The IRS has issued a list of 68 occupations, with occupation codes, that may have qualifying tip income, while also indicating that the list may be further modified.

 Schedule 1-A instructions, which have not yet been issued as of this writing, are to address situations with more than one employer. Another line is to include qualified tips from a trade or business, which are to be reported on Form 1099-NEC, Box 1, Form 1099-MISC, Box 3, or Form 1099-K. The qualified tips may not exceed the net profit from the trade or business, and instructions are to address situations with more than one trade or business.

The total of these sums is then to be compared to the $25,000 limit on deductible qualified tips. MAGI is then compared to the phase-out range of $150,000 ($300,000 for joint filers) for the final deduction calculation.

The proposed regulations on the tip income deduction include a discussion of what constitutes tips paid in cash or cash equivalents; that the tips must be received from customers or through a mandatory or voluntary tips sharing arrangement; that the tips must be voluntary and not subject to negotiation; and may not be a service charge unless there is an option to modify or disregard the charge.

The regulations also discuss categories of workers not eligible for the tip deduction, including specialized services trades or businesses, where the business depends primarily on the reputation of its owners or employees, performing artists, and athletes. It also excludes illegal activity, prostitution, and pornographic activity, although working for a business that violates the law in some other respects may not be disqualifying.

Guidance is still to be forthcoming for 2025 where tip and non-tip income are not stated separately. Employers and their payroll administrators will want to start looking at segregating qualifying tips from other tips. Consideration might be given to removing any fixed service charges that will not qualify for the tip deduction. Note should also be taken of which occupation codes qualify for the deduction.

Overtime

Part III of Schedule 1-A addresses overtime. Qualified overtime compensation is to be inserted from Form W-2, Box 1, Form 1099-NEC, Box 1, or Form 1099-MISC, box 3. 

The instructions to be issued will clarify how to handle situations where the required information does not appear on those forms for 2025 and how to determine what constitutes qualified overtime. These sums are then compared to the deduction limit of $12,500 ($25,000 for joint filers). Then MAGI is compared to the phase-out range of $150,000 ($300,000 for joint filers), with the calculation resulting in the qualified overtime deduction.

Employers should take steps to try to identify and segregate qualifying overtime from non-qualifying overtime. Overtime is more likely to qualify if it is being paid in accordance with Fair Labor Standards requirements.

Car loan interest

Part IV of Schedule 1-A addresses the new car loan interest deduction. Schedule 1-A refers to the instructions for determining qualified passenger vehicle loan interest, with interest on not only Schedule 1-A but also Schedules C, E or F. Those interest amounts are to be supported by third-party reporting by the lender. 

Vehicle identification numbers for up to two vehicles can be listed on the schedule, with the instructions to address more than two vehicles. The total interest is then compared to the $10,000 deduction limit. Next, MAGI is compared to the phase-out limit of $100,000 ($200,000 for joint filers) for calculation of the final deduction.

This deduction is less likely to impact payroll. Care should be taken to make sure that the new vehicle qualifies for the deduction, such as a VIN beginning with 1, 4 or 5 indicating assembly in the U.S. Commercial vehicles do not qualify for the deduction — it must be for personal use.

The Senior Deduction

Part V of Schedule 1-A addresses the $6,000 senior deduction, which also does not have payroll impact. The senior deduction is only available if the taxpayer and spouse have valid Social Security numbers and, if married, a joint return is filed. MAGI is compared to the phase-out limits of $75,000 ($150,000 for joint filers). The amount by which MAGI exceeds the phase-out amount, if any, is multiplied by 6%, and that amount is subtracted from the $6,000 limit. This sum is then included as a below-the-line deduction if the taxpayer has a valid Social Security number and was born before Jan. 2, 1961. It is also included again if the spouse has a valid Social Security number and was born before Jan. 2, 1961.

Part VI of Schedule 1-A then adds the totals from the four deductions, which is then entered on Form 1040, line 13b or 1040NR line 13c.

Trump Accounts

Employers should also anticipate possible involvement with the set up of Trump Accounts. The accounts are available to children born starting in 2025; however, due to administrative issues, the accounts cannot be set up until Jan. 1, 2026. 

Of the $5,000 in annual funding of the accounts, up to $2,500 may come from employers. Another $1,000 in seed money will come from the federal government. Employers will need to decide if they want to participate in funding Trump Accounts and set up the payroll procedures to do so by the end of 2025.

2026 Draft Form W-2

While the IRS has announced that they will not update the 2025 Form W-2, the agency has issued a draft 2026 Form W-2. Box 14 is divided into Box 14a and 14b. Box 14a is to be used for various items such as state disability insurance taxes withholding, union dues, uniform payments, health insurance premiums deducted, non-taxable income, or educational assistance payments. Box 14b is to be used for reporting the taxpayer’s tip occupation code. Box 12 has several new codes: TA for employer contributions to Trump Accounts, TP for qualified tips, and TT for qualified overtime compensation. 

Additional IRS guidance will direct employers as to how to report these items on the 2025 Form W-2.

Summary

Employers, payroll administrators, and self-employed persons should begin to take steps to identify qualifying tips and overtime and to be able to supply the information to the IRS necessary to support tip and overtime deductions and any employer contributions to Trump Accounts. 

At this point in time, we still await further guidance on these below-the-line deductions and guidance on qualified tip and overtime reporting. Hopefully, some of this additional guidance will be forthcoming in the near future.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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Accounting

Automated Tax Compliance and Global Regulatory Harmonization in 2026

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Corporate tax accounting departments are navigating an era of unprecedented regulatory complexity as global tax harmonization frameworks take full effect alongside real-time digital tax reporting mandates. Tax directors and accounting teams are adopting cloud-based tax compliance automation tools to manage multi-jurisdictional tax liabilities and satisfy stringent reporting rules across international jurisdictions.

Implementation of Global Minimum Tax Provisions
The implementation of international tax reform agreements—notably the Pillar Two global minimum tax framework—has reshaped multinational corporate tax planning. Multinational enterprises with consolidated revenues exceeding established thresholds must ensure an effective tax rate of at least 15% across every jurisdiction in which they operate.

Accounting teams are implementing specialized tax calculation modules integrated directly into enterprise resource planning (ERP) platforms. These automated tools calculate effective tax rates per country, identify top-up tax liabilities, and generate standardized compliance documentation required by national tax authorities.

Real-Time Digital Invoicing and E-Reporting Mandates
Tax authorities across Europe, Latin America, and Asia-Pacific have enacted mandatory electronic invoicing (e-invoicing) and continuous transaction controls (CTC). Under these systems, corporate transaction data must be submitted electronically to government portals in real time at the point of sale or invoice issuance.

This shift toward continuous digital tax reporting eliminates traditional annual tax audits in favor of ongoing automated compliance monitoring. Accounting departments are upgrading invoicing software to ensure seamless XML data formatting, digital signature authentication, and real-time validation against tax authority databases.

Automation and Data Analytics in Corporate Tax Strategy
To keep pace with dynamic tax legislation, tax departments are transitioning from reactive compliance teams to proactive strategic advisors. Machine learning algorithms analyze corporate transactional data to identify tax credits, research and development (R&D) incentives, and cross-border transfer pricing adjustments.

By automating routine tax return filings and calculations, corporate tax directors can focus on long-term capital structuring, evaluating the tax implications of corporate mergers, and optimizing international supply chain networks.

Strategic Priorities for Tax Executives
1. ERP System Upgrades: Ensure enterprise software is capable of generating real-time, granular tax data required for global minimum tax compliance.
2. E-Invoicing Integration: Implement scalable e-invoicing platforms to satisfy regional continuous transaction control regulations.
3. Strategic Tax Analytics: Utilize predictive tax modeling tools to evaluate structural changes in corporate operations and cross-border trade.

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