IRS Issues Multiple Guidance FAQs on Employer-Related Issues and the One Big Beautiful Bill

IRS Issues Multiple Guidance FAQs on Employer-Related Issues and the One Big Beautiful Bill
October 28, 2025 153 view(s)
IRS Issues Multiple Guidance FAQs on Employer-Related Issues and the One Big Beautiful Bill

On July 4th, 2025, President Donald J. Trump signed the One Big Beautiful Bill (OBBB) into law. Overall, according to the Congressional Summary, the OBBB reduces taxes and adjusts spending for various federal programs. The bill also increases the statutory debt limit and otherwise addresses agencies and programs throughout the federal government. As such, these updates have turned the OBBB into one of the most recent major employment laws that employers must comply with.  Since the signing of the OBBB, many federal agencies have enacted new laws and regulations to address the new bill. One such federal agency, the Internal Revenue Service (IRS), released new guidance just this past week on developments related to employment and the OBBB. In late September, the IRS, along with the United States Department of the Treasury (Treasury), released new guidance on proposed “No Tax on Tips” regulations. Specifically, this deduction is included within the One Big Beautiful Bill.

Transition Relief for Businesses Reporting Car Loan Interest

Firstly, on October 21st, 2025, the Treasury and the IRS provided transitional guidance for certain businesses. Accordingly, any companies that are required to report car loan interest under the One Big Beautiful Bill (OBBB) are affected. Explicitly, Notice 2025-57 provides penalty relief and guidance to specific lenders for new information reporting requirements for car loan interest received in 2025.

Generally, this relief is for lenders and other interest recipients who are required to:

  • file information returns with the IRS,
  • provide statements to borrowers showing the total amount of interest received on qualified passenger vehicle loans, and
  • provide other information related to the loan.

Under Notice 2025-57, the IRS will consider that lenders have met their reporting obligations for interest received on a qualified passenger car loan in 2025 if they make a statement available to the buyer indicating the total amount of interest received.


Markedly, the Treasury and the IRS state that this new benefit allows certain taxpayers to deduct interest paid on a qualified passenger vehicle loan during a taxable year beginning after December 31st, 2024, and before January 1st, 2029, provided the loan is incurred after December 31st, 2024, and the vehicle is purchased for personal use.

Employee Retention Credits Under the One Big Beautiful Bill

Secondly, on October 22nd, 2025, the IRS issued frequently asked questions regarding the limitations on Employee Retention Credits (ERCs) and refunds. Moreover, these ERCs are those claimed for the third and fourth quarters of 2021 that were filed after January 31st, 2024. Enacted under the OBBB, the federal agency created Fact Sheet 2025-07, which was released to provide “general information to taxpayers and tax professionals as expeditiously as possible.”

Overall, the new fact sheet discusses:

  • The new limitation on ERCs and refunds
  • When a claim is considered timely
  • Appeals rights on newly denied and disallowed claims

Examining the New Form 1099-K Threshold

Lastly, on October 23rd, 2025, the IRS released frequently asked questions regarding the dollar threshold for filing Form 1099-K under the One Big Beautiful Bill. Generally, Form 1099-K is an IRS information return used to report certain payments to improve voluntary tax compliance. Payment card companies, payment apps, and online marketplaces are required to file Form 1099-K with the IRS each year. They must also send a copy to businesses that accept direct payments by credit or bank card for the sale of goods or the provision of services.


Specifically, Fact Sheet 2025-08 discusses the change in the reporting threshold for businesses that receive payments through payment apps or online marketplaces (also known as third-party settlement organizations or TPSOs) for goods and services. Previously, under the American Rescue Plan Act of 2021 (ARPA), TPSOs were required to file Form 1099-K for any payee that received more than $600 in total payments. Now, under the One Big Beautiful Bill, TPSOs are not required to file a Form 1099-K unless the gross amount of reportable payment transactions to a payee exceeds $20,000 and the number of transactions exceeds 200. However, some states may still have lower Form 1099-K reporting requirements, and those remain in effect.


Employer Takeaways

In conclusion, as previously mentioned, the One Big Beautiful Bill has ramifications that affect most aspects of the federal government. That being said, it also affects many different types of employers across the country. Since this blog post discusses only three pieces of guidance released by two agencies this past week, there may be additional resources your business needs to be aware of. If you have any questions about how the OBBB affects you and your company, please consult your local labor office or seek the advice of your legal counsel.