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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

SEC’s Semiannual Reporting Proposal Faces Investor Pushback: What CFOs Need to Know

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U.S. Securities and Exchange Commission (SEC)

A proposal from the U.S. Securities and Exchange Commission to potentially shift some public companies away from quarterly financial reporting toward a semiannual model is drawing significant pushback from investors, even as it continues moving through the regulatory process. The debate has direct implications for corporate finance teams, auditors, and the broader transparency of U.S. capital markets.

What the SEC Proposed

According to a summary published by accounting advisory firm Cohen & Co., the SEC issued a proposed rule on May 19, 2026, aimed at simplifying financial reporting requirements for many U.S. public companies. The proposal would potentially reduce the frequency of certain mandatory disclosures from quarterly to semiannual, a structural change that has not been made to core U.S. reporting requirements in decades.

The proposal follows an extended debate within U.S. policy circles, with proponents arguing that reduced reporting frequency could lower compliance costs and free up management time for longer-term strategic planning rather than quarter-to-quarter results management.

Why Investors Are Pushing Back

Comment letters submitted in response to the proposal have been extensive, and according to Cohen & Co.’s review of the public record, investors “appear to be largely opposed” to the shift, viewing frequent interim reporting as a core benefit of U.S. capital markets relative to other jurisdictions.

Accounting and law firms have taken a more measured position, generally urging any changes to remain aligned with the Financial Accounting Standards Board (FASB), whose existing disclosure requirements and guidance are built around a quarterly reporting cadence. A shift to semiannual reporting without corresponding changes to FASB guidance could create friction between SEC filing requirements and GAAP-based disclosure expectations.

Lessons From the U.K. Experience

The debate is not without precedent. The United Kingdom moved away from mandatory quarterly reporting for listed companies in 2014, returning to a semiannual disclosure requirement. According to Cohen & Co.’s analysis, that experience offers a cautionary data point: there was no measurable increase in capital expenditure or R&D investment following the change, while analyst coverage of affected companies declined as reliable interim information became less available — a particular risk for smaller and newly public companies that rely on analyst coverage to maintain investor visibility.

Practical Implications for Finance Teams

Beyond the debate over disclosure philosophy, the proposal carries practical complications. Many companies have debt covenants and credit agreements structured around quarterly financial delivery; a shift to semiannual reporting could require renegotiating those terms. Reduced reporting frequency would also extend the “window of market silence” between disclosures, a factor that governance and investor-relations teams would need to manage carefully to avoid information asymmetry.

Separately, and unrelated to the reporting-frequency debate, the SEC and FASB have continued finalizing more routine updates this year. New Accounting Standards Updates are taking effect for December 31, 2026, fiscal year-ends covering income tax disclosures, credit loss measurement, induced debt conversions, and stock compensation, according to Eide Bailly’s review of 2026 ASU activity. Additional guidance on paid-in-kind dividends and environmental credits is also on the near-term horizon.

What to Watch Next

The semiannual reporting proposal remains in the comment and review phase, and no final rule has been adopted as of this writing. Finance leaders should monitor the SEC’s regulatory agenda for further movement, while treating the current quarterly reporting requirement as the operative standard until any final rule is issued and an effective date is set.

Given the extent of investor opposition documented in the comment file, a full shift to mandatory semiannual reporting appears more likely to result in either a scaled-back compromise or continued study rather than swift adoption — though the SEC’s ultimate direction remains uncertain.

 

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Accounting

AI-Driven Automation and Continuous Accounting Frameworks

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The accounting profession is undergoing a fundamental structural transition as enterprise finance departments shift from periodic month-end closes toward automated continuous accounting models. By integrating specialized machine learning algorithms directly into enterprise resource planning (ERP) platforms, chief accounting officers are transforming financial reporting from a retrospective exercise into a real-time operational asset.

The Shift from Periodic Close to Continuous Financial Reporting
Traditional accounting workflows heavily relied on manual data reconciliation, spreadsheet calculations, and multi-week closing cycles at the end of each fiscal period. In contrast, continuous accounting frameworks utilize automated software agents to process, validate, and post transactional data in real time as business activities occur.

Automated bank reconciliation tools cross-reference incoming bank feeds, invoice records, and purchase orders automatically. By resolving transactional variances instantly throughout the month, corporate accounting teams eliminate the traditional workload spikes associated with quarterly and annual closes.

Machine Learning in Audit Trails and Anomaly Detection
Advanced natural language processing (NLP) and machine learning tools are redefining internal audit and financial control environments. Automated systems analyze 100% of general ledger entries, identifying anomalous transactions, duplicate payments, and unauthorized journal entries in real time.

Rather than relying on random statistical sampling, corporate internal auditors can focus their attention on high-risk flags automatically surfaced by algorithmic monitoring platforms. This continuous risk assessment strengthens internal controls over financial reporting (ICFR) and significantly reduces fraud risk.

Evolving Roles for Accounting Professionals
As routine data entry and manual reconciliation tasks become fully automated, the skill set required for accounting professionals is shifting toward data analysis, system design, and strategic business advisory.
– Systems Governance: Accountants are increasingly responsible for monitoring algorithmic accuracy and managing data integration pipelines.
– Business Partnership: Finance professionals leverage real-time financial dashboards to advise operational leaders on margin management and working capital allocation.
– Regulatory Compliance Management: Accounting teams utilize automated platforms to ensure compliance with dynamic tax codes and international accounting standards.

Core Implementation Recommendations
1. Deploy Automated Reconciliation Tools: Integrate continuous transaction processing modules into existing enterprise ERP architectures.
2. Establish Algorithmic Governance Controls: Implement strict internal testing protocols to ensure automated accounting rules comply with GAAP/IFRS standards.
3. Reskill Accounting Teams: Invest in training finance staff on data analytics, workflow automation, and predictive financial modeling.

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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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