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What Employers Must Know About 2026 Payroll Changes Under the Big Beautiful Tax Bill

Overview

The One Big Beautiful Bill Act (OBBBA) introduces federal income tax deductions for qualified tips (up to $25,000) and qualified overtime premiums (up to $12,500) beginning in the 2025 tax year.

While these amounts may reduce an employee's personal tax liability, they are not automatically exempt from federal income tax withholding at the time of payment. Employers must continue to track and report these earnings while withholding Social Security, Medicare, and applicable state taxes as required by current IRS guidance.

Big Beautiful Tax Bill

What Are Qualified Tips?

Qualified tips must be:

  • Voluntarily paid by customers (not mandatory service charges)
  • Earned in occupations that customarily and regularly receive tips
  • Properly reported through payroll

Note: Mandatory service charges (for example, an automatic 15–20% service fee) are not tips and do not qualify.

What Are Qualified Overtime (OT)?

Qualified overtime (OT) is:

  • Pay for hours worked beyond normal work hours
  • Paid at a premium rate (typically 1.5x regular pay)
  • Earned by employees in eligible occupations
  • Separately tracked and reported in payroll

Important: Federal Income Tax Withholding

Employers must continue to withhold federal income tax on qualified tips and qualified overtime.

The “no federal tax on tips / overtime” benefit is:

  • A federal income tax deduction claimed by employees on their personal tax return
  • Not an automatic exemption from federal withholding at payroll time

Employers should not stop federal income tax withholding based on qualification status.

Can ezPaycheck Payroll Software Support Qualified Tips and Overtime?

Yes. ezPaycheck 2026 adds two new payment types:

  • Qualified Tips
  • Qualified Overtime

These payment types help employers track and report amounts correctly on paychecks, reports, and Form W-2.

What Are the Employer Responsibilities Under the Big Beautiful Tax Bill?

Employers must:

  • Continue normal federal income tax withholding
  • Withhold Social Security and Medicare taxes
  • Pay FUTA on qualified tips and qualified OT
  • Track qualified tips and OT separately for reporting
  • Accurately report all wages on Form W-2

How to Classify and Report Qualified Tips and Overtime

To properly classify and report qualified tips and overtime, employers should:

  • Use ezPaycheck 2026's new payment types
  • Label the payment as "Qualified Tips" or "Qualified Overtime" when creating the payment

ezPaycheck 2026 will automatically withhold payroll taxes for qualified tips and overtime, and fill in 2026 Form W-2 (which is available in November or December 2026) with the qualified tips and overtime.

Is There a Cap on Qualified Tips and Overtime?

Yes.

  • Employees may claim a maximum deduction of $25,000 per year (combined tips + OT)
  • Income phase-out rules apply at higher income levels

Employers do not enforce caps or income limits during payroll processing.

Should Employers Stop Labeling Qualified Tips/OT after Limits Are Reached?

No.

Employers should continue labeling all qualified tips and overtime, even if:

  • The employee exceeds the $25,000 annual cap, or
  • The employee exceeds the income phase-out threshold

Caps and income limits are handled by the employee on their personal tax return, not by payroll.

What Should Employers Communicate to Employees?

Employers should inform employees that:

  • Federal income tax is still withheld on tips and overtime
  • Any tax benefit is claimed on the employee's personal tax return
  • Eligibility, caps, and phase-outs are determined by the IRS, not the employer

IRS Guidance Pages

This information is provided for general educational purposes only and does not constitute tax or legal advice. We are a software developer and cannot determine whether any specific employee's tips or overtime qualify for federal deductions, or how those deductions apply to an individual tax return. Employers and employees should consult the IRS guidance and/or a qualified tax professional for their specific situation.

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