Tax Compliance Alert: H.R. 1 ("One Big Beautiful Bill" Act) - July 2025 Update

H.R. 1, the “One Big Beautiful Bill” Act[i] was signed into law on July 4, 2025. Below are a number of sections which may have a considerable impact on employers and employees. The Act requires the U.S. Department of the Treasury to provide guidance to implement certain sections. IRS has recently summarized several sections of the Act with new individual income tax deductions and promises to provide guidance.[ii] As guidance becomes available, updates and action items will be provided.

“No Tax on Tips”

• Sec. 70201 (IRC new Section 224): No tax on tips
  • Qualified tips are reported as an income tax deduction.
  • $25,000 deduction limit
  • Deduction begins to phase out when modified adjusted gross income (MAGI) exceeds $150,000 and $300,000 for joint filers.
  • Deduction is allowed for non-itemizers.
  • Deduction is available to taxpayers with a work-eligible SSN.
  • Effective retroactively 1/1/2025 through 12/31/2028
  • Transition rule: For cash tips reported prior to 1/1/2026, employers would be permitted to approximate tips “by any reasonable method specified by the Secretary.”
  • Deduction is available to “traditional” tipped industries, including beauty service industry.
  • Treasury and IRS will provide guidance, including a list of occupations customarily and regularly receiving tips.

“No Tax on Overtime”

• Sec. 70202 (IRC new Section 225): No tax on overtime
  • FLSA overtime paid in excess of the regular rate is reported as an income tax deduction.
  • Deduction is limited to $12,500 and $25,000 for joint filers.
  • Deduction phases out when MAGI exceeds $150,000 and $300,000 for joint filers.
  • Report qualified OT separately on W-2
  • Deduction is allowed for non-itemizers.
  • Deduction is available to taxpayers with a work-eligible SSN.
  • Effective retroactively 1/1/2025 through 12/31/2028
  • Transition rule: For OT reported prior to 1/1/2026, employers would be permitted to approximate qualifying OT “by any reasonable method specified by the Secretary.”
  • Treasury and IRS will provide guidance. 

Trump Accounts

• 70204 (New IRC Section 530A) Trump Accounts
  • The Act creates a new custodial account for qualifying children akin to a Section 408(a) IRA, but not a Roth IRA, with a contribution limit of $5,000 (adjusted for inflation).
  • Optional employer contributions up to $2,500 to the account would be excluded from the employee’s gross income.
  • Guidance and regulations from the Treasury Department are expected.

Paid Family and Medical Leave

• 70304 (IRC Section 45S) Paid Family and Medical Leave Credit
  • By extending and enhancing the paid family and medical leave tax credit, employers may elect to claim the credit based on either a percentage of qualified leave wages or a percentage of insurance premiums paid or incurred for taxable years beginning after December 31, 2025.

Dependent Care Assistance Program (Dependent Care FSA)  

• 70404 (IRC Section 129): Dependent Care Flexible Spending Account Limits Increase
  • The dependent care FSA contribution limit will increase from $5,000 to $7,500 (from $2,500 to $3,750 for married individuals filing separately), effective for taxable years beginning after December 31, 2025.

Information Reporting Threshold Changes - 1099 Reporting

• 70433 (IRC Section 6041(a)): Information Reporting Threshold Changes
  • The threshold for reporting certain payments and remuneration for services, including payments reported on Forms 1099-MISC and 1099-NEC, increases from $600 to $2,000 for payments made after December 31, 2025. The threshold is expected to be adjusted for inflation annually for any calendar year after 2026.

Health Savings Accounts

• 71306 and 71308 (IRC Section 223(c)): Enhancing Choice for Patients
  • Permitting telehealth coverage without requiring a deductible under High Deductible Health Plans becomes permanent, retroactive to tax years beginning after December 31, 2024.
  • Fees for direct primary care service arrangements can be paid from HSAs, with limitations, effective for months beginning after December 31, 2025.

Next Steps…

Dominion Payroll is actively reviewing the new law and planning product updates to support its requirements. We'll continue monitoring regulatory agencies for future guidance, including guidance addressing the retroactive provisions for overtime and tips. 

Content originally created by isolved, created Monday, July 14th, 2025

¹The official title of H.R. 1 as passed is ‘‘An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14.’’ The popular House title, “One Big Beautiful Bill,” was removed from the Act. https://www.congress.gov/bill/119th-congress/house-bill/1/text

²IRS FS-2025-03 https://www.irs.gov/newsroom/one-big-beautiful-bill-act-tax-deductions-for-working-americans-and-seniors