Trade Associations
Here's a look at documents from national and international trade associations
Featured Stories
NGFA Applauds Senate Agriculture Committee for Advancing U.S. Grain Standards Act Reauthorization
ARLINGTON, Virginia, Oct. 22 -- The National Grain and Feed Association issued the following news release on Oct. 21, 2025:
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NGFA applauds Senate Agriculture Committee for advancing U.S. Grain Standards Act Reauthorization
The National Grain and Feed Association (NGFA) today applauded the Senate Agriculture Committee for marking up and advancing legislation to reauthorize the U.S. Grain Standards Act (USGSA). This action demonstrates strong bipartisan recognition of the essential role that official grain inspection and weighing play in supporting U.S. agriculture, trade, and food security.
"This
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ARLINGTON, Virginia, Oct. 22 -- The National Grain and Feed Association issued the following news release on Oct. 21, 2025:
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NGFA applauds Senate Agriculture Committee for advancing U.S. Grain Standards Act Reauthorization
The National Grain and Feed Association (NGFA) today applauded the Senate Agriculture Committee for marking up and advancing legislation to reauthorize the U.S. Grain Standards Act (USGSA). This action demonstrates strong bipartisan recognition of the essential role that official grain inspection and weighing play in supporting U.S. agriculture, trade, and food security.
"Thisis a pivotal moment for the grain value chain," said NGFA President and CEO Mike Seyfert. "By moving this bill forward, the Senate Agriculture Committee is helping to ensure continuity, reliability and innovation in the grain inspection system that underpins the competitiveness of U.S. grain in global markets."
NGFA also extended its appreciation to Senate Agriculture Committee Chair John Boozman (R-Ark.) and Ranking Member Amy Klobuchar (D-Minn.) for their leadership in securing a markup that reflects the needs of the industry. Their commitment to shepherding the legislation through committee highlights the bipartisan nature of this effort and the critical importance of USGSA reauthorization.
Key provisions of the legislation under consideration align with NGFA priorities, including:
* Renewing vital inspection and weighing authorities scheduled to expire
* Strengthening transparency and accountability at the Federal Grain Inspection Service (FGIS)
* Leveraging modern technology to enhance efficiency and reduce burdens
* Adjusting the scope of user fee caps to broaden resource capacity for essential services
"Modernization, efficiency and stability are nonnegotiables for the participants across the supply chain -- from producers, elevators and processors to exporters," Seyfert added. "This markup is a strong step forward, and we urge the full Senate to act swiftly to pass the reauthorization so it can reach President Trump's desk."
NGFA looks forward to continuing to work with Senate leaders, committee members, and staff to finalize and secure passage of the United States Grain Standards Act reauthorization.
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Original text here: https://www.ngfa.org/usda-under-secretaries-confirmed-copy/
[Category: Agriculture]
ISDA and Tokenovate Launch Taskforce to Develop Smart Contract Framework Within the CDM
NEW YORK, Oct. 22 (TNSrpt) -- The International Swaps and Derivatives Association issued the following news release on Oct. 21, 2025:
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ISDA and Tokenovate Launch Taskforce to Develop Smart Contract Framework within the CDM
ISDA and Tokenovate have today announced the establishment of a new taskforce within the Fintech Open Source Foundation (FINOS) to accelerate operationalization of the Common Domain Model (CDM).
The initiative responds to growing market demand for standardized, interoperable post-trade processing and will deliver an open-source, production-ready library of CDM functions
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NEW YORK, Oct. 22 (TNSrpt) -- The International Swaps and Derivatives Association issued the following news release on Oct. 21, 2025:
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ISDA and Tokenovate Launch Taskforce to Develop Smart Contract Framework within the CDM
ISDA and Tokenovate have today announced the establishment of a new taskforce within the Fintech Open Source Foundation (FINOS) to accelerate operationalization of the Common Domain Model (CDM).
The initiative responds to growing market demand for standardized, interoperable post-trade processing and will deliver an open-source, production-ready library of CDM functionsand workflows, freely available to market participants.
The taskforce's initial focus will be the automation of interest rate resets, referencing the 2021 ISDA Interest Rate Derivatives Definitions. This process underpins trillions of dollars of financial contracts globally but remains largely manual and inconsistent across firms. The shift to risk-free reference rates has made this challenge more acute. These benchmarks, introduced to replace legacy interbank offered rates, require daily rate observations, business-day adjustments and compounding calculations that demand precision and consistency. Automating this process through the CDM represents a major step toward real-time, programmable post-trade infrastructure.
Built in alignment with concepts set out in an ISDA whitepaper, Smart Derivatives Contracts: From Concept to Construction, the taskforce is building a smart contract model within the CDM to translate ISDA's legal and operational standards into executable form. The CDM already provides a canonical representation of the contract layer, defining standardized product terms, calculation conventions and event structures. The smart contract model extends this framework by introducing the executable logic that will power the automation of derivatives products, in line with ISDA's foundational legal and operational standards.
Designed to be technology-agnostic, the initiative delivers immediate operational and strategic benefits by eliminating interpretative differences and reconciliation breaks, enabling deterministic, auditable execution and promoting interoperability with digital infrastructure, tokenization and artificial-intelligence-driven solutions.
"ISDA is committed to promoting greater standardization and efficiency in derivatives markets. By embedding the CDM into executable smart contract logic, we are taking a significant step toward fully digitized, interoperable post-trade processes. Our collaboration with Tokenovate and the FINOS community will help ensure that ISDA's legal and operational standards are not just documented, but operationalized -- enabling real-time automation and reducing friction across global derivatives markets," said Olivier Miart, Co-head of Digital Transformation at ISDA.
"For more than 40 years, ISDA has set the standards that underpin the global derivatives market. During my time at ISDA, I was fortunate to contribute to that journey, from early work on smart derivatives contracts to the development of the CDM. This collaboration marks the next stage in that evolution: moving from conceptual design to reality. Embedding ISDA's legal and operational standards directly into code establishes a common foundation for automation, interoperability and innovation across the market. Tokenovate is proud to work with ISDA to help bring that vision to life," said Ciaran McGonagle, Chief Legal & Product Officer at Tokenovate.
The CDM is an open, standardized representation of trade events, processes and data structures for derivatives and other financial products. Developed under the FINOS open-source governance framework, the CDM provides a single, consistent foundation for trade lifecycle automation, regulatory reporting and interoperability across institutions and infrastructures. More information on the CDM is available here (https://www.isda.org/isda-solutions-infohub/cdm/).
For further information on the taskforce and to register interest, please click here (https://url.usb.m.mimecastprotect.com/s/sepLCp9jEkT188OMhPf0uGQaWq?domain=github.com). Send an email to FINOS to subscribe for updates by clicking here (https://url.usb.m.mimecastprotect.com/s/f5cGCqAkGlfK55k0uXh6uEp9jE?domain=lists.finos.org/).
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REPORT: https://www.isda.org/a/cHvEE/Smart-Derivatives-Contracts-From-Concept-to-Construction-Oct-2018.pdf
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Original text here: https://www.isda.org/2025/10/21/isda-and-tokenovate-launch-taskforce-to-develop-smart-contract-framework-within-the-cdm/
[Category: Financial Services]
ICPA Seeks Safe Harbor for 2025 Reporting Requirements of Tips and Overtime
NEW YORK, Oct. 22 -- The Association of International Certified Professional Accountants issued the following news release:
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ICPA Seeks Safe Harbor for 2025 Reporting Requirements of Tips and Overtime
Washington, D.C. - In a letter submitted to the U.S. Department of the Treasury and the Internal Revenue Service (IRS), the American Institute of CPAs (AICPA) requested guidance related to the 2025 reporting and substantiation requirements regarding the deductions for qualified tips and qualified overtime compensation.
The One Big Beautiful Bill Act, or H.R. 1 (Act), created Internal Revenue
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NEW YORK, Oct. 22 -- The Association of International Certified Professional Accountants issued the following news release:
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ICPA Seeks Safe Harbor for 2025 Reporting Requirements of Tips and Overtime
Washington, D.C. - In a letter submitted to the U.S. Department of the Treasury and the Internal Revenue Service (IRS), the American Institute of CPAs (AICPA) requested guidance related to the 2025 reporting and substantiation requirements regarding the deductions for qualified tips and qualified overtime compensation.
The One Big Beautiful Bill Act, or H.R. 1 (Act), created Internal RevenueCode (IRC) section 224 and section 225, which temporarily allows a deduction for individual taxpayers for qualified tips and qualified overtime compensation. To claim the deductions, separate reporting of qualified tips and qualified overtime compensation is required to be included on information returns, including Form W-2 and Form 1099-NEC, Nonemployee Compensation. The Act amended relevant Chapter 61 rulesto require information reporting of qualified overtime compensation and qualified tips by employers and businesses to align with the requirement in section 224 and section 225 that qualified tips and qualified overtime compensation be included on information returns. However, the 2025 version of these forms, which is the current revision, does not allow for this reporting. Additionally, the IRS recently announced that there will be "no changes to individual information returns or withholding tables for 2025 under the One Big Beautiful Bill Act,"including no revisions to Form W-2, Form 1099-NEC, Form 1099-MISC, Miscellaneous Information, and Form 1099-K, Payment Card and Third Party Network Transactions.
To address this, the AICPA's letter recommends that Treasury and IRS:
* Provide guidance including a safe harbor for businesses for the 2025 tax year allowing for alternative methods of reporting and use of alternative documentation to report under section 224(a) and section 225(a).
* Include a safe harbor that permits individuals and tax return preparers to rely on the alternative information provided to determine the deductions including:
*Box 7 of Form W-2
*Information provided by the employer or payor in any format (e.g., pay stubs or letters)
*Individual taxpayer representations of occupations, tip sheets, hours worked logs and other
documentation.
* Include examples in the guidance indicating the type of documentation that will satisfy the information reporting safe harbors.
"Employers and payors are unsure of how to satisfy information reporting required under section 224 and section 225 in order for individuals to be eligible for these deductions," says Scott Klein, Senior Manager, AICPA Tax Policy & Advocacy. "Additionally, tax return preparers and individuals preparing their own tax returns are unsure which type of alternative documentation they can rely on to support the deductions for qualified tips and qualified overtime compensation. The AICPA urges the IRS to accept our recommendations and provide this much needed clarification."
View letter here: https://www.aicpa-cima.com/resources/download/aicpa-comment-letter-on-tips-and-overtime-deductions
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About the American Institute of CPAs
The American Institute of CPAs (AICPA) is the world's largest member association representing the CPA profession, with 397,000 members and a history of serving the public interest since 1887. AICPA members represent many areas of practice, including business and industry, public practice, government, education, and consulting. A founding member of the Association of International Certified Professional Accountants, the AICPA sets ethical standards for the profession, attestation standards, and U.S. auditing standards for private companies, not-for-profit organizations, and federal, state, and local governments. It develops and grades the Uniform CPA Examination, offers specialized credentials, partners across the profession to build future talent, and drives continuing education to advance the vitality, relevance, and quality of the profession.
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Original text here: https://www.aicpa-cima.com/news/article/aicpa-seeks-safe-harbor-for-2025-reporting-requirements-of-tips-and-overtime
[Category: Accounting]
House Bill Would Mandate Timely Notices of TRICARE Coverage Changes
WASHINGTON, Oct. 22 -- The Military Officers Association of America issued the following news on Oct. 21, 2025:
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House Bill Would Mandate Timely Notices of TRICARE Coverage Changes
By Kevin Lilley
A bipartisan House bill would require TRICARE beneficiaries approaching a change in their coverage - a family member aging out of their current plan, for example - to receive a series of notices before the change takes place.
The TRICARE Transition Transparency Act (H.R. 5586) mandates email notices at the 180-day, 60-day, and 30-day marks before any deadlines to act. The bill would ensure families
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WASHINGTON, Oct. 22 -- The Military Officers Association of America issued the following news on Oct. 21, 2025:
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House Bill Would Mandate Timely Notices of TRICARE Coverage Changes
By Kevin Lilley
A bipartisan House bill would require TRICARE beneficiaries approaching a change in their coverage - a family member aging out of their current plan, for example - to receive a series of notices before the change takes place.
The TRICARE Transition Transparency Act (H.R. 5586) mandates email notices at the 180-day, 60-day, and 30-day marks before any deadlines to act. The bill would ensure familiesare aware of upcoming changes, such as the need to switch to TRICARE Young Adult to maintain TRICARE coverage when a dependent turns 21 (or 23 if a full-time student), or the move into Medicare and TRICARE For Life coverage when a beneficiary turns 65.
"TRICARE is a complex benefit, and awareness of pending eligibility changes is key to ensuring seamless coverage and access to health care," MOAA President and CEO Lt. Gen. Brian T. Kelly, USAF (Ret), said in a statement announcing the bill's introduction by Rep. Jen Kiggans (R-Va.). "MOAA appreciates Rep. Kiggans' leadership on this important legislation, and we look forward to supporting her efforts to improve TRICARE communication to military families."
Initial cosponsors of the legislation include Reps. Patrick Ryan (D-N.Y.), Robert Wittman (R-Va.), and Maggie Goodlander (D-N.H.). The text of the bill also is included in the House version of the FY 2026 National Defense Authorization Act (NDAA), which passed the chamber Sept. 10. The Senate's version does not include the provision.
"Too often, families are caught off guard by coverage changes that create confusion, gaps in care, or unexpected costs," Kiggans said in the announcement. "This bipartisan bill ensures TRICARE beneficiaries get repeated, clear reminders, well in advance, so they can plan, budget, and make informed decisions."
Along with the personalized communication, the bill requires Pentagon officials to mount an outreach campaign discussing the coverage changes on the TRICARE website, on social media, and with family readiness groups. It also requires an annual report on these outreach efforts, along with recommendations for improvement.
The bill would prevent coverage from being "ripped away without notice," Ryan said in the announcement, adding that "we have to be all-hands-on-deck to deliver much-needed relief to military families across the country."
For updates on this and other MOAA advocacy priorities, visit MOAA's Legislative Action Center.
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About the Author
Kevin Lilley
Lilley serves as MOAA's digital content manager. His duties include producing, editing, and managing content for a variety of platforms, with a concentration on The MOAA Newsletter and MOAA.org. Follow him on X: @KRLilley
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Original text here: https://www.moaa.org/content/publications-and-media/news-articles/2025-news-articles/health-care-and-earned-benefits/house-bill-would-mandate-timely-notices-of-tricare-coverage-changes/
[Category: National Defense]
EEI Welcomes Bipartisan Committee Vote to Advance the Fix Our Forests Act
WASHINGTON, Oct. 22 -- The Edison Electric Institute issued the following news release on Oct. 21, 2025:
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EEI Welcomes Bipartisan Committee Vote to Advance the Fix Our Forests Act
Edison Electric Institute (EEI) President and CEO Drew Maloney today issued the following statement after the U.S. Senate Committee on Agriculture, Nutrition, and Forestry voted to advance the Fix Our Forests Act:
"Wildfires are a national challenge that require national solutions, and this legislation represents a critical step forward in reducing wildfire risks and safeguarding communities. We urge senators
... Show Full Article
WASHINGTON, Oct. 22 -- The Edison Electric Institute issued the following news release on Oct. 21, 2025:
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EEI Welcomes Bipartisan Committee Vote to Advance the Fix Our Forests Act
Edison Electric Institute (EEI) President and CEO Drew Maloney today issued the following statement after the U.S. Senate Committee on Agriculture, Nutrition, and Forestry voted to advance the Fix Our Forests Act:
"Wildfires are a national challenge that require national solutions, and this legislation represents a critical step forward in reducing wildfire risks and safeguarding communities. We urge senatorsto act quickly to pass this bill, work with the House, and ultimately deliver the Fix Our Forests Act to the President's desk."
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About EEI
EEI is the association that represents all U.S. investor-owned electric companies. Our members provide safe, reliable electricity for nearly 250 million Americans, and operate in all 50 states and the District of Columbia. As a whole, the electric power industry supports more than 7 million jobs in communities across the United States. In addition to our U.S. members, EEI has more than 50 international electric companies as International Members, and hundreds of industry suppliers and related organizations as Associate Members.
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Original text here: https://www.eei.org/News/news/All/eei-welcomes-bipartisan-committee-vote-to-advance-the-fix-our-forests-act
[Category: Energy]
American Fintech Council Asks CFPB to Preserve Open Banking Innovation and Uphold Fee Prohibitions
WASHINGTON, Oct. 22 -- The American Fintech Council, an organization that says it promotes a transparent, inclusive, and customer-centric financial system, issued the following news release:
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American Fintech Council (AFC) Asks CFPB to Preserve Open Banking Innovation and Uphold Fee Prohibitions
AFC, in addition to joint trade effort, is calling for protection of consumers' right to their own financial data in response to Bureau ANPR
*
The American Fintech Council (AFC), the premier industry association representing responsible fintech companies and innovative banks, submitted comments
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WASHINGTON, Oct. 22 -- The American Fintech Council, an organization that says it promotes a transparent, inclusive, and customer-centric financial system, issued the following news release:
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American Fintech Council (AFC) Asks CFPB to Preserve Open Banking Innovation and Uphold Fee Prohibitions
AFC, in addition to joint trade effort, is calling for protection of consumers' right to their own financial data in response to Bureau ANPR
*
The American Fintech Council (AFC), the premier industry association representing responsible fintech companies and innovative banks, submitted commentsto the Consumer Financial Protection Bureau (CFPB) regarding its reconsideration of the Personal Financial Data Rights Rule under Section 1033 of the Dodd-Frank Act. AFC urged the Bureau to preserve consumers' right to access and share their financial data, prohibit data access fees, and ensure the United States remains a global leader in open banking.
"Consumers have a right to control their own financial data, and use it to access the financial tools that work best for them," said Phil Goldfeder, CEO of the American Fintech Council. "Imposing fees on consumer data is a direct threat to responsible innovation, competition, and the millions of Americans who rely on responsible fintech tools to manage their finances each day."
AFC's comment letter, submitted in addition to a broader joint filing alongside other trade associations, emphasizes that Section 1033 clearly establishes consumers' right to access their data through an agent, trustee, or representative, and that the Act's language clearly prohibits financial institutions from charging for such access. AFC also called on the Bureau to modernize certain provisions of the previous final rule, including overly restrictive limits on the secondary use of consumer data and annual reauthorization requirements, both of which risk curbing responsible innovation and reducing consumer choice.
"Strong, standards-based open banking policies empower consumers and keep the U.S. financial system competitive with leading economies around the world," said Ian P. Moloney, SVP and Head of Policy and Regulatory Affairs at AFC. "By preserving the existing fee prohibitions and further clarifying how responsible innovators can use consumer-permissioned data, the CFPB can ensure the open banking market continues to grow in a way that benefits consumers, innovators, and the broader economy."
In the letter, AFC also reaffirmed its commitment to working with the CFPB and Trump Administration to strengthen consumer data rights and foster a thriving, inclusive financial marketplace.
A standards-based organization, AFC is the premier trade association representing the largest financial technology (Fintech) companies and innovative banks offering embedded finance solutions. AFC's mission is to promote a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.
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Original text here: https://www.fintechcouncil.org/press-releases/american-fintech-council-afc-asks-cfpb-to-preserve-open-banking-innovation-and-uphold-fee-prohibitions
[Category: Financial Services]
AICPA Seeks Safe Harbor for 2025 Reporting Requirements of Tips and Overtime
WASHINGTON, Oct. 22 -- The American Institute of CPAs issued the following news release on Oct. 21, 2025:
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AICPA Seeks Safe Harbor for 2025 Reporting Requirements of Tips and Overtime
In a letter (https://www.aicpa-cima.com/resources/download/aicpa-comment-letter-on-tips-and-overtime-deductions) submitted to the U.S. Department of the Treasury and the Internal Revenue Service (IRS), the American Institute of CPAs (AICPA) requested guidance related to the 2025 reporting and substantiation requirements regarding the deductions for qualified tips and qualified overtime compensation.
The One
... Show Full Article
WASHINGTON, Oct. 22 -- The American Institute of CPAs issued the following news release on Oct. 21, 2025:
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AICPA Seeks Safe Harbor for 2025 Reporting Requirements of Tips and Overtime
In a letter (https://www.aicpa-cima.com/resources/download/aicpa-comment-letter-on-tips-and-overtime-deductions) submitted to the U.S. Department of the Treasury and the Internal Revenue Service (IRS), the American Institute of CPAs (AICPA) requested guidance related to the 2025 reporting and substantiation requirements regarding the deductions for qualified tips and qualified overtime compensation.
The OneBig Beautiful Bill Act, or H.R. 1 (Act), created Internal Revenue Code (IRC) section 224 and section 225, which temporarily allows a deduction for individual taxpayers for qualified tips and qualified overtime compensation. To claim the deductions, separate reporting of qualified tips and qualified overtime compensation is required to be included on information returns, including Form W-2 and Form 1099-NEC, Nonemployee Compensation. The Act amended relevant Chapter 61 rulesto require information reporting of qualified overtime compensation and qualified tips by employers and businesses to align with the requirement in section 224 and section 225 that qualified tips and qualified overtime compensation be included on information returns. However, the 2025 version of these forms, which is the current revision, does not allow for this reporting. Additionally, the IRS recently announced that there will be "no changes to individual information returns or withholding tables for 2025 under the One Big Beautiful Bill Act,"including no revisions to Form W-2, Form 1099-NEC, Form 1099-MISC, Miscellaneous Information, and Form 1099-K, Payment Card and Third Party Network Transactions.
To address this, the AICPA's letter recommends that Treasury and IRS:
- Provide guidance including a safe harbor for businesses for the 2025 tax year allowing for alternative methods of reporting and use of alternative documentation to report under section 224(a) and section 225(a).
- Include a safe harbor that permits individuals and tax return preparers to rely on the alternative information provided to determine the deductions including:
* Box 7 of Form W-2
* Information provided by the employer or payor in any format (e.g., pay stubs or letters)
* Individual taxpayer representations of occupations, tip sheets, hours worked logs and other documentation.
- Include examples in the guidance indicating the type of documentation that will satisfy the information reporting safe harbors.
"Employers and payors are unsure of how to satisfy information reporting required under section 224 and section 225 in order for individuals to be eligible for these deductions," says Scott Klein, Senior Manager, AICPA Tax Policy & Advocacy. "Additionally, tax return preparers and individuals preparing their own tax returns are unsure which type of alternative documentation they can rely on to support the deductions for qualified tips and qualified overtime compensation. The AICPA urges the IRS to accept our recommendations and provide this much needed clarification."
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About the American Institute of CPAs
The American Institute of CPAs (AICPA) is the world's largest member association representing the CPA profession, with 397,000 members and a history of serving the public interest since 1887. AICPA members represent many areas of practice, including business and industry, public practice, government, education, and consulting. A founding member of the Association of International Certified Professional Accountants, the AICPA sets ethical standards for the profession, attestation standards, and U.S. auditing standards for private companies, not-for-profit organizations, and federal, state, and local governments. It develops and grades the Uniform CPA Examination, offers specialized credentials, partners across the profession to build future talent, and drives continuing education to advance the vitality, relevance, and quality of the profession.
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October 17, 2025
Ms. Helen Morrison, Benefits Tax Counsel, Department of the Treasury, 1500 Pennsylvania Ave., NW, Washington, DC 20220
Ms. Christa Bierma, Associate Benefits Tax Counsel, Department of the Treasury, 1500 Pennsylvania Ave., NW, Washington, DC 20220
Ms. Amalia C. Colbert, Commissioner, (SB/SE), Internal Revenue Service, 1111 Constitution Ave., NW, Washington, DC 20224
Mr. Philip Lindenmuth, Acting Associate Chief Counsel (EEE), Internal Revenue Service, 1111 Constitution Ave., NW, Washington, DC 20224
Re: Request for transition relief related to Section 70201 and Section 70202 of H.R. 1
Dear Ms. Morrison, Ms. Bierma, Ms. Colbert, and Mr. Lindenmuth:
The American Institute of CPAs (AICPA) appreciates the efforts of the Department of Treasury ("Treasury") and the Internal Revenue Service (IRS) regarding the issuance of the draft Form W-2, Wage and Tax Statement, and Form W-2C, Corrected Wage and Tax Statement, for tax year 2026, to accommodate the reporting of the new federal income tax deductions for qualified tips and qualified overtime compensation, and the occupation codes as enacted in Section 70201 and Section 70202 of H.R. 1.0F [1] ("the Act"). We also applaud the release of Proposed Regulations titled Occupations that Customarily and Regularly Received Tips; Definition of Qualified Tips [REG-110032-25]. The AICPA is writing to respectfully request that guidance be issued related to the 2025 reporting and substantiation requirements regarding the deductions for qualified tips1F [2] and qualified overtime compensation.2F [3]
Background
The Act created Internal Revenue Code (IRC) section3F [4] 224 and section 225, which temporarily allows a deduction for individual taxpayers for qualified tips and qualified overtime compensation, respectively, as these terms are defined in the statutes and relevant guidance. For tax years beginning after December 31, 2024, and before December 31, 2028, eligible taxpayers can deduct up to $25,000 of qualified tips from their adjusted gross income. Additionally, eligible employees can deduct up to $12,500 ($25,000 for married taxpayers filing jointly) of qualified overtime compensation. Both deductions phase out if modified adjusted gross income is over $150,000 ($300,000 for married taxpayers filing jointly).
To claim the deductions, separate reporting of qualified tips and qualified overtime compensation is required to be included on information returns, including Form W-2 and Form 1099-NEC, Non-employee Compensation. The Act amended relevant Chapter 61 rules4F 5 to require information reporting of qualified overtime compensation and qualified tips by employers and businesses to align with the requirement in section 224 and section 225 that qualified tips and qualified overtime compensation be included on information returns. However, the 2025 version of these forms, which is the current revision, does not allow for this reporting. Additionally, the IRS recently announced that there will be "no changes to individual information returns or withholding tables for 2025 under the One Big Beautiful Bill Act," 5F 6 including no revisions to Form W-2, Form 1099-NEC, Form 1099-MISC, Miscellaneous Information, and Form 1099-K, Payment Card and Third Party Network Transactions.
Overview
A deduction for qualified tips is allowed only for the amount of tips reported to a taxpayer on an information return provided to them by an employer or other payor or reported by the taxpayer on Form 4137, Social Security and Medicare Tax On Unreported Tip Income, (or successor).6F [7]
Additionally, a qualifying occupation is also required to be reported on the relevant information return.7F [8] A deduction for qualified overtime compensation is allowed for the amount received during the taxable year and included on statements furnished to the individual by an employer or other payor.8F [9]
Because the 2025 Form W-2 and Form 1099 do not provide designated fields to report the amount of qualified tips and qualified overtime compensation, or the occupation codes, employers and payors are currently unsure of how to satisfy information reporting as is required under section 224 and section 225 in order for individuals to be eligible for these deductions. Additionally, tax return preparers and individuals preparing their own tax returns are unsure which type of alternative documentation they can rely on to support the deductions for qualified tips and qualified overtime compensation.
Recommendation
The AICPA recommends that Treasury and the IRS provide guidance including a safe harbor for businesses for the 2025 tax year allowing for alternative methods of reporting and use of alternative documentation to report under section 224(a) and section 225(a).
We also recommend that Treasury and the IRS include a safe harbor that permits individuals and tax return preparers to rely on the alternative information provided to determine the deductions including:
- Box 7 of Form W-2
- Information provided by the employer or payor in any format (e.g., pay stubs or letters) - Individual taxpayer representations of occupations, tip sheets, hours worked logs and other documentation.
These safe harbors are supported by the transition relief rules provided in the Act sections 70201(k) and 70202(h).
Additionally, we recommend including examples in the guidance indicating the type of documentation that will satisfy the information reporting safe harbors.
Analysis
The current revision of the relevant information returns does not accommodate the reporting required under sections 224 and section 225. Additionally, given the retroactive nature of the provisions, some employers may not be able to timely segregate qualified tips or qualified overtime compensation for the 2025 tax year. Therefore, we suggest providing safe harbors with respect to qualified tips and qualified overtime compensation, as defined by the Act, for 2025 information reporting.
With respect to qualified tips, the Act permits the Secretary of the Treasury ("Secretary") to prescribe any reasonable method of approximating a separate accounting for amounts designated as qualified tips for 2025 Form 1099 reporting; it did not extend the relief to Form W2 reporting. With respect to qualified overtime compensation, the Act permits the Secretary to prescribe any reasonable method of approximating separate accounting for amounts designated as qualified overtime compensation for all 2025 information reporting.
Since the IRS has stated that information reporting will not change for 2025, we recommend that Treasury and the IRS provide a safe harbor stating that a reasonable method used to approximate a separate accounting of qualified tips and qualified overtime compensation will satisfy information reporting requirements for 2025. If the information reporting safe harbor is satisfied, a taxpayer required to report qualified tips and qualified overtime compensation on statements furnished to individuals under section 224(a) and section 225(a) will not fail to satisfy their reporting requirements.
Additionally, we recommend that Treasury and the IRS provide a safe harbor under which an individual taxpayer will not fail to be eligible for the deductions allowed under section 224(a) and section 225(a) by reason of qualified tips and qualified overtime compensation, respectively, not being included on 2025 information returns as required under those sections and permitting an individual preparing their own income tax return, or a tax return preparer preparing and signing income tax returns, to rely on the alternative information reporting when determining the deductions.
We also suggest providing examples in the guidance of the type of documentation that will satisfy the safe harbor methods of reporting. The following examples illustrate potential Ms. Helen Morrison reasonable alternative methods of reporting and reliance on them to determine the amounts of the deductions under the safe harbors for qualified overtime compensation and qualified tips: Example 1
Employer provides Employee A with a 2025 Form W-2 and a one-page typed statement indicating "Your overtime pay above regular wages is $5,000." The tax return preparer receives the Form W-2 and the one-page typed statement from their client, Employee A. The employer is considered to have met the information reporting safe harbor related to qualified overtime compensation. The tax return preparer can rely on the Form W-2 and one-page statement for 2025, which indicates $5,000 of overtime, to determine the qualified overtime deduction, unless the employee indicates that they did not work more than 40 hours a week such that the overtime was not paid under the Fair Labor Standards Act (FLSA). Alternatively, if preparing their own return, Employee A can rely on the information when determining the qualified overtime deduction.
Example 2
Employer provides Employee B with a 2025 Form W-2 showing $17,500 of tips in box 7, Social Security Tips. Employee B provides this information to their tax return preparer with an explanation of their job position at their employer. The employer is considered to have met the information reporting safe harbor. The tax return preparer can rely on the amount of tips reported in box 7 of the W-2, which indicates that Employee B received $17,500 in tips to determine the qualified tips deduction, after confirming Employee B's position is listed in the proposed regulations and has a Treasury Tipped Occupation Code. Alternatively, if preparing their own return, Employee B can rely on the information when determining the qualified tip deduction.
Example 3
Employer provides Employee C with a 2025 Form W-2 and a year-end paystub reporting $10,000 of overtime pay above regular wages, along with an employer statement indicating that overtime hours are based on several different types of overtime, such as Union overtime, FLSA overtime, and California overtime. The employee does not know which hours relate to each overtime system. The employer is considered to have met the information reporting safe harbor.
Employee C provides this information to their tax return preparer. The tax return preparer can rely on the paystub which indicates $10,000 of overtime above regular wages to determine the qualified overtime deduction. Alternatively, if preparing their own return, Employee C can rely on the information when determining the qualified overtime deduction.
Example 4
Employer provides Employee D with a 2025 Form W-2 reporting $8,000 in box 7, Social Security Tips, and $2,000 in box 8, Allocated Tips. The employee did not receive the $2,000 in allocated tips but does not have documentation to prove it and therefore must include the $2,000 in income. Employee D provides the Form W-2 to their tax return preparer. The employer is considered to have met the information reporting safe harbor. The tax return preparer can rely on the W-2 for 2025, which indicates that Employee D received $10,000 in tips to determine the qualified tips deduction, after confirming Employee D's position is listed in the proposed regulations and has a Treasury Tipped Occupation Code. Alternatively, if preparing their own return, Employee D can rely on that information when determining their qualified tip deduction.
Example 5
An on-demand delivery driver receives Form 1099-NEC reporting a total of $8,000 in box 1 and a letter indicating that the driver received approximately $700 in tips. The delivery driver keeps a daily log of earnings, tips and expenses reflecting total tips of $1,600. The payor is considered to have met the information reporting safe harbor. The delivery driver may rely on the tip log which indicates $1,600 of tips and Form 1099-NEC for 2025, to determine the qualified tips deduction when preparing their own tax return. Alternatively, a tax return preparer could rely on that information when determining the qualified tips deduction.
Example 6
A rideshare driver receives a 2025 Form 1099-K reporting a total of $21,000 in box 1a. The rideshare driver also receives a statement from the Third-Party Settlement Organization (TPSO) indicating that they received $1,300 in tips, which was included in the $21,000 in box 1a. However, the rideshare driver kept records indicating that they received a total of $1,800 in tips. The payor is considered to have met the information reporting safe harbor. The rideshare driver can rely on the information received from the TPSO and their own records indicating receipt of $1,800 of tips for 2025 to determine the qualified tips deduction when preparing their own tax return. Alternatively, a tax return preparer could rely on that information when determining the qualified tips deduction.
Example 7
A self-employed hair stylist received $53,000 in tips in 2025. The hair stylist receives no information returns. The hair stylist keeps a business log of tips received. The hair stylist can rely on their own records to determine the qualified tips deduction when preparing their own tax return. Alternatively, a tax return Ms. Helen Morrison preparer can rely on the business log when determining the qualified tip deduction.
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The AICPA is the world's largest member association representing the accounting profession, with more than 397,000 members in the United States and worldwide, and a history of serving the public interest since 1887. Our members advise clients on federal, state and international tax matters and prepare income and other tax returns for millions of Americans. Our members provide services to individuals, not-for-profit organizations, small and medium-sized businesses, as well as America's largest businesses.
We appreciate your consideration of these comments and welcome the opportunity to discuss these issues further. If you have any questions, please contact; Amie Kuntz, chair of the AICPA Individual and Self-Employed Technical Resource Panel, at (515) 551-4296 or Amie.Kuntz@rubinbrown.com; Anne Bushman, Chair, AICPA Employee Benefits Taxation Technical Resource Panel, at (202) 370-8213, or anne.bushman@rsmus.com; Kristin Esposito, AICPA, Director - Tax Policy & Advocacy, at Kristin.Esposito@aicpa-cima.com; Scott Klein, AICPA, Senior Manager - Tax Policy & Advocacy, at Scott.Klein@aicpa-cima.com; or me at (610) 217-4495 or CheriFreeh@gmail.com.
Sincerely,
Cheri H. Freeh, CPA, CGMA
Chair, AICPA Tax Executive Committee
cc: Ms. Lynne Camillo, Deputy Associate Chief Counsel (EEE), Internal Revenue Service
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Footnotes:
1. Pub. L. No. 119-21.
2. As defined in section 224(d).
3. As defined in section 225(c).
4. All references to "section" are to the Internal Revenue Code of 1986, as amended, and all references to "Treas.
Reg. Sec.," "Prop. Reg. Sec.," and "regulations" are to U.S. Treasury regulations promulgated thereunder, unless otherwise specified.
5. Sections 6041, 6041A, 6050W and 6051.
6. IR-2025-82.
7. Section 224(a).
8. Prop. Reg. Sec. 1.224(f)(1) provides a table of "Occupations that Customarily and Regularly Received Tips on or Before December 31, 2024" with a corresponding Treasury Tipped Occupation Code (TTOC) that is proposed to be used to satisfy this requirement beginning with the 2026 tax year.
9. Section 225(a).
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Original text here: https://www.aicpa-cima.com/news/article/aicpa-seeks-safe-harbor-for-2025-reporting-requirements-of-tips-and-overtime
[Category: Accounting]
