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Tip Credit

Akerman LLP

Recent DOL Opinion Letter on Tip Pooling

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I recently received a U.S. Department of Labor opinion letter addressing a client inquiry about whether an oyster shucker working in the “front of the house” may participate in a tip pool under the Fair Labor Standards Act....more

McGuireWoods LLP

Department of Labor Issues Four Opinion Letters on FLSA and FMLA

McGuireWoods LLP on

On Sept. 30, 2025, the U.S. Department of Labor issued four opinion letters on a range of issues under the Fair Labor Standards Act (FLSA) and Family and Medical Leave Act (FMLA). Three opinion letters offer guidance on...more

Womble Bond Dickinson

Shuckers in the Pool: DOL Clarifies Tip-Pooling Rules for the Hospitality Industry

Womble Bond Dickinson on

The Department of Labor’s (DOL) September 30, 2025 Opinion Letter FLSA2025-03 brings welcome clarity for restaurants and hospitality employers navigating complex tip pooling requirements. By way of background, a DOL...more

Ice Miller

DOL Opinion Letters Clarify Tip Pools, Emergency Pay, Joint Employment, and FMLA Leave

Ice Miller on

On September 30, 2025, the Department of Labor (DOL) Wage and Hour Division (WHD) issued four opinion letters regarding tip pooling for certain front-of-house restaurant employees, emergency pay for firefighters under the...more

Phelps Dunbar

New Oyster Cult: Giving (Tip) Credit to the Frontman

Phelps Dunbar on

DOL’s latest opinion letter cracks open tip pooling rules for customer-facing oyster shuckers. The world of tip pooling under the Fair Labor Standards Act (FLSA) is a perennial source of confusion and litigation for...more

Jackson Lewis P.C.

DOL’s First Batch of Trump 2.0 Opinion Letters Address Tip Pools, Emergency Pay + Joint Employment

Jackson Lewis P.C. on

The U.S. Department of Labor Wage and Hour Division issued three new opinion letters interpreting the Fair Labor Standards Act (FLSA) on Sept. 30, 2025. The letters are the first of the new administration and clarify...more

Constangy, Brooks, Smith & Prophete, LLP

Wage-hour opinion letters address tip pooling, emergency pay, and FLSA and FMLA compliance

On September 30, before the federal government shutdown, the Wage and Hour Division of the U.S. Department of Labor issued four opinion letters on issues of interest to employers. All four of the letters were written by...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOL Not Shucking Tradition: Recent Opinion Letter on Tip Pool Inclusion

One day before the government shutdown, on September 30, 2025, the U.S. Department of Labor (DOL) issued four opinion letters, including FLSA2025-03, which condones including front-of-house oyster shuckers in traditional tip...more

Littler

Department of Labor Issues Opinion Letter Regarding Employees Who Customarily and Regularly Receive Tips

Littler on

On September 30, 2025, the U.S. Department of Labor (DOL) issued an opinion letter reaffirming its longstanding approach to determining which employees “customarily and regularly” receive tips for purposes of compliance with...more

Fisher Phillips

From Joint Employers to Oyster Shuckers: DOL Issues Opinion Letters on Hospitality Sector Wage Issues

Fisher Phillips on

Is an oyster shucker who works in the “front of the house” allowed to share in the tip pool? Are a hotel restaurant and related members club joint employers for overtime purposes? The US Department of Labor (DOL) recently...more

Vedder Price

Treasury Department Issues List of Jobs Qualifying for New Tip Income Deduction Under “One Big Beautiful Bill” Act

Vedder Price on

As we discussed here, on July 4, 2025, President Donald Trump signed the “One Big Beautiful Bill” Act (OBBBA) into law, which included a provision establishing a new temporary above-the-line tax deduction for “qualified tip...more

Fisher Phillips

Here Are the Jobs Covered By the “No Tax on Tips” Law – and What Employers Should Do Next

Fisher Phillips on

Employers got a sneak peek at the jobs that will qualify for the “no tax on tips” deduction over the holiday weekend thanks to a list obtained by Axios. The September 1 release provides the first real clarity on which...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

District of Columbia’s Pause on Tipped Wage Increase Signals Grim Future for Initiative 82

In November 2022, voters in Washington, D.C., approved Initiative 82, the “District of Columbia Tip Credit Elimination Act of 2022,” which set forth a gradual elimination of the use of the tip credit in the District by 2027. ...more

Fisher Phillips

Employer Cheat Sheet for Workplace Laws Taking Effect July 1

Fisher Phillips on

Most employers are prepared for new laws at the start of each year – but did you know that a heap of new workplace laws take effect at the halfway point? Here’s your employer cheat sheet to prepare for July 1 effective dates…...more

Fox Rothschild LLP

Washington, DC Pauses Upcoming Increase to the Tipped Minimum Wage

Fox Rothschild LLP on

The District of Columbia passed emergency legislation on June 3, 2025 that paused an increase to the tipped minimum wage from $10 per hour to $12 per hour, which was originally set to take effect on July 1, 2025. At least for...more

Littler

Colorado Enacts Increased Wage Act Penalties and Enforcement, Allows Local Governments to Increase Tip Credit

Littler on

Colorado has enacted House Bill 25-1001, which significantly amends the state’s wage and hour laws by enhancing enforcement mechanisms, expanding employer liability, and strengthening employee protections. The law will take...more

Fox Rothschild LLP

House and Senate Overtime and Tip Tax Proposals: What Employers Need to Know

Fox Rothschild LLP on

Competing House and Senate bills have the potential to reshape how the IRS taxes tips and overtime wages. The Senate recently passed the “No Tax on Tips Act” while the House budget reconciliation bill proposes deductions for...more

Davidoff Hutcher & Citron LLP

Tip Pooling and Tip Credit Compliance: A Guide for New York Restaurant Owners

New York restaurant owners must navigate complex tip pooling and tip credit regulations to ensure compliance with federal and state labor laws. Failure to follow these rules can result in lawsuits, back wages, and penalties....more

Mandelbaum Barrett PC

Tip Credit in New Jersey: What Bill A-5433 Means for Restaurants and Workers

Mandelbaum Barrett PC on

As the New Jersey legislature considers eliminating the tip credit—a move that would require all restaurant workers to be paid the full minimum wage regardless of tips—the hospitality and business communities are pushing...more

Fisher Phillips

Where Do We Stand? An Action Plan for Employers on Tip Credit Compliance and the 80/20 Rule

Fisher Phillips on

Many employers in hospitality and other service industries take the tip credit toward their minimum wage obligation under federal wage and hour law – but complying with evolving rules has been challenging in recent years....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New Jersey Bill to Eliminate Minimum Wage Tip Credit Will Impact Hospitality Industry

New Jersey stands at a crossroads regarding the compensation of tipped workers. Introduced on March 10, 2025, Assembly Bill A5433 proposes a significant change to the New Jersey Wage and Hour Law: phasing out the “tip...more

Benesch

No Tax on Tips! What President Trump’s Promise May Mean for Your Business

Benesch on

If you’re a political nerd like me, you may have observed then-candidate and now President Donald J. Trump’s pledge to eliminate taxes on tips. In fact, he doubled down on this promise in his speech to Congress on March 4,...more

Amundsen Davis LLC

Department of Labor Clarifies Management Cannot Keep Tips From a Tip Pool and Reverts Back to the Dual Jobs Rule

Amundsen Davis LLC on

In January, the U.S. Department of Labor (DOL) issued an opinion letter clarifying managers and supervisors still cannot receive or keep tips, including from a tip pool. This came shortly after the DOL restored the dual...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Michigan Amends Its Minimum Wage Law With Additional Changes

On February 21, 2025, Governor Gretchen Whitmer signed Senate Bill 8, amending the Improved Workforce Opportunity Wage Act (IWOWA)—Michigan’s minimum wage law—which was set to be reinstated effective the same day. The...more

Jackson Lewis P.C.

A Mixed Bag for Michigan Employers: Legislature Accelerates Minimum Wage Increases but Saves the Tip Credit

Jackson Lewis P.C. on

The Michigan legislature amended the state’s Wage Act on Feb. 20, 2025, in a compromise measure that accelerated the schedule of minimum wage increases but staved off a complete phaseout of the tip credit for workers who...more

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