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Tax Strategy: Options for claiming the 2025 deductions for tips and overtime

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Under Notice 2025-62, the Internal Revenue Service provided guidance to employers whose employees receive tips or overtime as to the procedures to follow for documenting qualified tips and qualified overtime on 2025 tax returns. 

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That guidance basically asked employers to use their best efforts to provide that documentation; however, recognizing that the legislation creating those deductions was enacted halfway through 2025 and employers may not have the ability to identify qualifying tips and overtime under the new law, the IRS announced that no penalties would be imposed on employers that were unable to document qualified tips and overtime for 2025.

Now, in Notice 2025-69, the IRS has also provided guidance to taxpayers seeking to report their qualified tips and overtime on the 2025 tax return. Taxpayers are not provided with any specific waiver of penalties. However, they are given several options based on the information, or lack of information, provided by their employers. The law normally requires employees to report only the qualified tips and qualified overtime reported to the IRS by their employers. These notices provide an exception to this requirement for 2025 tax returns only.

Tips under Notice 2025-69

Employers are not required to separately account for cash tips on IRS forms or statements furnished to individuals for 2025. Notice 2025-69 states that an employee may treat the requirement that qualified tips be included on a statement furnished to the employee for 2025 as satisfied if the employee’s cash tips are properly reported on the employee’s W-2 without regard to whether there is a separate account for the total amount of cash tips. The employee may calculate the amount of qualified tips under one of the following options:

  1. Use the total amount of Social Security tips reported in Box 7 of Form W-2;
  2. Use the total amount of tips reported by the employee to the employer on Form 4070 (“Employee’s Report of Tips to Employer”), or any similar substitute form; or,
  3. If an employer voluntarily chooses to report the amount of an employee’s cash tips in Box 14 of Form W-2 (or a separate statement), the employee may use that amount to report qualified tips. 
  4. An employee may also include any amount listed on Line 4 of 2025 Form 4137 filed with the employee’s 2025 income tax return.
  • Occupation codes. Whether or not the employer has provided an occupation code for the employee, the employee is still responsible for determining whether the tips were received in an occupation that customarily and regularly received tips on or before Dec. 31, 2024, as provided by the Secretary of the Treasury. As of this writing, the Treasury has identified 68 qualifying occupation codes.
  • Specified service trades or businesses. In general, employees of specified service trades or businesses, such as accounting, law and other professions, are not considered eligible to receive qualified tips. However, for 2025, the IRS will treat an employee as having received tips in a trade or business that is not a SSTB if it is an occupation that is one of the occupation codes provided by the Secretary of the Treasury.
  • Non-employees. Similarly for non-employees, if the non-employee’s cash tips are included in the total amounts reported as other income on Form 1099-MISC, as non-employee compensation on Form 1099-NEC, or as payment card/third-party network transactions on Form 1099-K, then the non-employee may calculate qualified tips using earnings statements or other documentation to corroborate the calculation for 2025. The non-employee may also request additional information from the payor. The occupation code requirements and SSTB waiver for 2025 also apply to non-employees.

Notice 2025-69 also includes a few examples of calculating qualified tips.

Overtime under Notice 2025-69

Notice 2025-69 provides that payments in excess of the Fair Labor Standards Act-required premiums are not qualified overtime. Only the additional one-half of pay premium in excess of regular pay is considered qualified overtime. The employee should confirm that their employer is an FLSA employer.

For 2025, qualified overtime may be reported anywhere on Form W-2 or a separate statement. It also may be on Form 1099-NEC or 1099-MISC. For 2025, an employee may determine qualified overtime from any of the following:

  1. The employee was paid overtime compensation at a rate of 1½ times the regular rate for hours in excess of 40 hours per week and receives a statement separately accounting for overtime premiums;
  2. The employee was paid 1½ time over 40 hours; however, it was not separately stated. Employee may use one third of the total;
  3. If the employee was paid over 1½ time, use the appropriate fraction, e.g., if twice the regular rate, use one-fourth of the total;
  4. The adjustment under Nos. 2 or 3 above may be adjusted to correct an underestimation.
  5. Under any of the above methods, if no statement has been received, the individual may use a reasonable method using regular rate of pay and hours over 40 per week and any employer information provided.
  6. Public sector, hospital and residential care employees may use alternative overtime rules.

Several examples are also provided in the notice for calculating qualified overtime.

Summary

While the IRS is attempting to provide a great deal of flexibility in calculating qualified tips and qualified overtime for 2025, the various options may still be confusing for many taxpayers. The taxpayer must still have documentation of some form to support the deduction of tips and overtime. Taxpayers must also be able to establish that they fall into one of the accepted occupation codes. The taxpayer may also be on their own to make the calculation of qualifying tips and qualifying overtime without clear documentation from the employer or other payor. 

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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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