Year-End Tax

The IRS has officially released the final 2026 Form W-4, Employee’s Withholding Certificate, incorporating updates from the One Big Beautiful Bill Act (OBBBA). Following the August draft, the finalized form confirms structural and numeric changes designed to align withholding with new deduction and credit provisions under the OBBBA. The finalized form expands the Deductions Worksheet, clarifies exemption procedures, and adjusts credit values to reflect the updated Child Tax Credit of $2,200 per qualifying child, up from $2,000. The layout now totals five pages (including instructions), up from four in 2025. Key 2026 updates: Step 3: Claim Dependent and Other Credits Split structure retained: Lines 3(a) and 3(b) remain separate for qualifying children and other dependents. New value applied: The Child Tax Credit rises to $2,200 per child under OBBBA, while the $500 credit for other dependents is unchanged. Step 4: Other Adjustments The optional label has been removed. Step 4 now clearly defines its subsections. Step 4(b) explicitly states that if left blank, withholding defaults to the standard deduction. Exemption checkbox added: Employees can now claim exempt from withholding via a formal checkbox and certification, replacing the old handwritten “Exempt” notation. Expanded Deductions Worksheet (Page 4) The worksheet grows, occupying its own page, and now includes new categories introduced by OBBBA: Qualified tips. If your total income is less than $150,000 ($300,000 if married filing jointly), enter an estimate of your qualified tips up to $25,000 Qualified overtime compensation: If your total income is less than $150,000 ($300,000 if married filing jointly), enter an estimate of your qualified overtime compensation up to $12,500 ($25,000 if married filing jointly) of the “and-a-half” portion of time-and-a-half compensation. Qualified overtime compensation. If your total income is less than $150,000 ($300,000 if married filing jointly), enter an estimate of your qualified overtime compensation up to $12,500 ($25,000 if married filing jointly) of the “and-a-half” portion of time-and-a-half compensation. Qualified passenger vehicle loan interest. If your total income is less than $100,000 ($200,000 if married filing jointly), enter an estimate of your qualified passenger vehicle loan interest up to $10,000. The worksheet retains traditional itemized categories (medical/dental, SALT, mortgage interest, charitable gifts) but now concludes with a limitation section and a refreshed standard deduction table. These additions directly mirror OBBBA’s new income-based deductions. Why this matters: The 2026 Form W-4 signals a shift toward greater precision and legislative alignment. Employees with variable pay—especially tips, overtime, or new car loans—can now fine-tune withholding through targeted deduction lines. Employers gain clearer data inputs for payroll accuracy and reduced rework. The checkbox for exemption simplifies verification and year-end tracking. The child credit increase ensures calculations match the higher benefit created under OBBBA. Employer checklist: Update HRIS/payroll fields to accommodate the expanded Step 4(b) deductions and new exempt checkbox. Refresh employee guidance—including onboarding instructions, FAQ content, and self-service portals—to explain the new lines. Validate withholding logic against 2026 tax tables once released. Communicate early—especially to employees with tips, overtime, or auto-loan interest deductions. Employees, what to know: If you earn tips or overtime, bought a new car, or are 65 or older, you may qualify for new deductions under OBBBA. Use the updated worksheet to reflect these items and avoid over withholding. The IRS withholding estimator (https://www.irs.gov/individuals/tax-withholding-estimator) remains the best way to validate accuracy throughout the year. Key takeaway: The final 2026 Form W-4 transforms the withholding certificate into a more granular, data-driven tool. It brings OBBBA’s deductions and credit changes directly into payroll operations and requires employers to review system fields and training materials now to stay ahead of 2026 implementation.

As employers close out another year and prepare to adjust for another year of regulatory updates, we are reminded of some items that loom large for this year and next: Changes to this year’s Affordable Care Act (ACA) reporting requirements and a new Form W-2 for next year. Below is a closer look at the changes and what your organization can do to stay ahead of the regulatory curve. Changes to ACA and 1095-C Requirements Late 2024, Congress passed an act designed to allow applicable large employers some flexibility in how they furnish forms 1095-C to their employees. Employers are no longer required to automatically send 1095-C forms to all full-time employees. Employers wishing to take advantage of the new process must instead follow the specific alternative notice methodology enacted under the 2024 laws. Essentially, employers are considered compliant if they have posted a “clear, conspicuous and accessible” notice on their benefits website informing employees that they may request a copy of the form and how they may do so. If such a copy is requested, the employer must provide the copy by either January 31 or within 30 days of the request, whichever is later. The deadline for furnishing the 1095-C or posting the notice as to how to obtain the form is March 2, 2026. Employers opting for the alternative methodology must post the “how-to” notice by that time and leave it posted through October 15, 2026. It is important to note that employers wishing to use the alternative furnishment methodology ensure they adhere to the guidance provided in IRS Notice 2025-15, which states that employers wishing to provide the requested form in electronic format, first obtain electronic consent from the employee, much as they would prior to providing an electronic W-2. New Form W-2 for 2026 In addition to changes to ACA reporting, the IRS recently released a draft Form W-2 for Tax Year 2026. The new form, which has already been edited three times, introduces new codes for Box 12, and a new box 14b to account for items introduced in the One Big Beautiful Act. The new codes are TA, for newly created “Trump Accounts”, TP, for reporting qualified tips, and TT, for reporting qualified overtime.While no changes were made to the W-2 for this tax year, employers can take some solace in the IRS announcement that no penalties will be levied regarding OBBA reporting for the current tax year. Compliance minded employers should review these items and adjust their processes accordingly. At a minimum, preparation should include a) updating employee communications regarding requesting Form 1095-C, b) coordinating with payroll providers/vendors to prepare for 2026 W-2 changes, and c) ensure they are monitoring the IRS website for any changes or updates.

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