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In brief

Treasury and the IRS recently issued two notices regarding the new OBBBA qualified tips and qualified overtime for 2025. Notice 2025-62 relieves employers and payors from the reporting obligations associated with qualified tips and qualified overtime for 2025, acknowledging that employers and payors may not have the information or the systems in place to be able to comply with the reporting, and that the IRS did not update the relevant forms for the OBBBA changes. Notice 2025-69 assists taxpayers who receive overtime and tips in calculating the deductions for 2025 in the absence of information reporting from employers and payors and provides hints as to the information reporting that ultimately will be required of employers/payors.


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Author

Anne Batter is a partner in Baker McKenzie's Tax Practice Group with 25 years of tax experience. She focuses her practice on the tax treatment of executive compensation and fringe benefits arrangements. She also handles excise tax matters, particularly those involving the air transportation excise tax. She previously served as an attorney in the Income Tax & Accounting Division of the IRS’s Office of Chief Counsel and as attorney-advisor with the US Tax Court. Ms. Batter has been recognized by Legal 500 as a leading lawyer in the United States for complex executive compensation matters.

Author

Ligeia Donis is a partner in Baker McKenzie's Tax Practice Group, based in the Firm’s DC office. Ligeia advises multinational companies on compensation and benefits tax-related matters, including compliance, tax controversy and dispute resolution, and voluntary disclosures. Ligeia is a frequent speaker at professional association meetings, including the DC Bar Association, ABA, the American Payroll Association and Practicing Law Institute. She also is a member of the American Institute of Certified Public Accountants (AICPA), where she advocates for sound tax policy in the legislative, regulative and administrative arenas. Prior to joining Baker McKenzie, Ligeia was a partner at a specialized global mobility, tax and immigration services firm.

Author

Robin Samuel leads Baker McKenzie’s US Labor & Employment team, is co-chair of the Firm’s Workforce Redesign service line, and is a Steering Committee member for the North American Employment and Compensation practice. Robin also serves on the California offices’ leadership team. Robin is a Chambers-ranked attorney for California employment law, a Benchmark Litigation Labor & Employment Star, and a 2023 L.A. Business Journal Top 100 Lawyers award recipient. Robin is a frequent author and speaker for organizations such as SHRM, ACC, and the World Business Council for Sustainable Development.