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IRS Updates FAQs on the Qualified Overtime Compensation Deduction: Compliance Obligations for Employers

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On August 6, 2026, the IRS released Fact Sheet FS-2026-13, substantially revising and replacing FS-2026-01, its January 2026 guidance on the new deduction for qualified overtime compensation enacted by the One Big Beautiful Bill Act (OBBBA). The revised guidance reflects the transition from the temporary 2025 reporting relief period to a more formal compliance regime applicable for tax years 2026 through 2028.  As a reminder, the IRS provided transition penalty relief for tax year 2025…

SEC Proposes Scaled Back Executive Compensation Disclosure for Most Public Companies 

By and 4 Mins Read

On May 19, 2026, the SEC issued Release No. 33‑11419, proposing a fundamental shift in the public company reporting framework. While the focus of the Release is on capital markets access and filer status simplification, the proposal’s disclosure accommodations would significantly reduce executive compensation disclosure requirements for many U.S. public companies. If adopted, scaled executive compensation disclosure requirements would apply to all non‑accelerated filers—an expanded category that would include approximately 80% of current public companies. All…

Keys to Tax Compliance When a U.S. Nonresident Director Joins a U.S. Board

By 1 Min Read

U.S. companies are increasingly electing or appointing non-U.S. tax residents to serve on their boards of directors. When doing so, it is important to understand the U.S. and foreign tax obligations and issues that can arise. Compensation paid to a director who is not a U.S. tax resident is subject to U.S. federal withholding and specialized tax reporting requirements that differ from those applicable to U.S. tax resident directors. Additional complexities may arise in determining the portion…

IRS Issues 2025 Transition Relief and Hints at Future Tips and Overtime Information Reporting Obligations

By , and 13 Mins Read

The One, Big, Beautiful Bill Act (OBBBA), enacted July 4, 2025, creates new tax deductions for tax years 2025 through 2028 for recipients of qualified tips and qualified overtime compensation. The OBBBA amendments to the Code generally impose information reporting requirements, such as on Form W-2 or Form 1099, on the payors of qualified tips and overtime in order for the recipients of such compensation to be eligible to take the deductions. However, for tax year…

One Big Beautiful Bill Act Introduces New Excise Tax on Remittance Transfers

By , and 11 Mins Read

The One Big Beautiful Bill Act, enacted as Public Law 119-21 on July 4, 2025, introduces new section 4475,i which imposes a 1% excise tax on remittance transfers made after December 31, 2025. The provision was initially touted as one that “Makes America Win Again,” because it would affect only certain immigrants. As enacted, however, the excise tax applies equally to all individual taxpayers, whether US citizen, resident, or immigrant. It is unclear just how…

The Real Life of a CEO: Modern Day Issues Regarding Security, Accessibility and Travel Expectations

By and 1 Min Read

For the first time in nearly twenty years, the SEC is considering on a holistic basis whether the current executive compensation disclosure rules serve their core function of efficiently providing investors with material information on which to make voting and investment decisions.  On June 26, 2025, the SEC hosted a roundtable on executive compensation disclosure featuring various stakeholders, including advisors, investors, and directors, and their discussion touched on a wide range of topics.  In advance…

No Tax on Tips or Overtime in the OBBBA: What Employers Need to Know

By , , and 1 Min Read

On July 4, President Trump signed the ‘One Big Beautiful Bill Act’ into law, including provisions reducing federal income tax on qualified tips and overtime compensation. For employers, the new law raises a host of practical questions: In this video chat, our Employment & Compensation and Tax partners unpack this significant development in federal tax policy. Tune in to discover what these changes may mean for your operations, and for practical tips to navigate the new law.…

Senate Passes No Tax on Tips and Overtime Provisions

By and 9 Mins Read

Overview We reported in May on the provisions in the House’s One Big Beautiful Bill addressing two of President Trump’s campaign promises – no taxation of tips and overtime.  The Senate has now passed its version of the One Big Beautiful Bill, which includes its version of these provisions in sections 70201 and 70202.  See our prior blog post here for a detailed discussion of the House provisions.  While the basic structure of the provisions…

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