United States Tax Compliance and Filing Obligations: January 2026

The Regulatory Architecture of the 2026 Filing Season

To navigate the specific deadlines of January 2026, tax professionals and controllers must understand the structural changes governing the tax environment. This season is the first to implement retroactive provisions that fundamentally alter definitions of taxable wages.

The "One Big Beautiful Bill" (OBBB) Impact

Enacted in mid-2025 with retroactive effect to January 1, 2025, the OBBB changes the compliance landscape for the information returns filed in January 2026.

• No Tax on Tips: A deduction of up to $25,000 for "qualified tips" is available for tax years 2025 through 2028. This transforms Form 4070 from a liability document into a benefit-substantiation document.
• No Tax on Overtime: Overtime compensation is now partially exempt or deductible, placing a burden on payroll departments to retroactively identify and report overtime pay distinctly from regular wages on 2025 W-2s.
• Electronic Filing: The Treasury Department has lowered the e-filing threshold to 10 returns in aggregate, mandating electronic submission for virtually all entities.

The "Weekend Rule" (IRC Section 7503)

Because January 31, 2026, falls on a Saturday, IRC Section 7503 dictates that deadlines shift to the next business day. Consequently, deadlines for furnishing W-2s, filing 1099-NECs, and filing Form 941 automatically move to Monday, February 2, 2026. This provides a critical 48-hour window for data validation.

*Strategic Implication: This shift provides a critical 48-hour window for last-minute data validation, particularly crucial given the new OBBB data requirements.

Jan 12 Deadline: Employee Tip Reporting

The first compliance hurdle occurs on Monday, January 12, 2026. This deadline applies to employees receiving tip income—a demographic now subject to intensified scrutiny and benefit under new legislation.

Form 4070 Mechanics

Employees who received $20 or more in cash tips in December 2025 must report this to their employer. Since the standard January 10 deadline is a Saturday, the report is due January 12. Accuracy here is paramount; under-reporting tips not only risks under-withholding penalties but now artificially reduces the "qualified tip" base eligible for the new federal income tax deduction.

Jan 15 Deadline: Estimated Tax & Cash Flow

Thursday, January 15, 2026, is the final installment deadline for 2025 estimated taxes for individuals (Form 1040-ES) and C Corporations (Form 1120-W).

The "January Return" Exception

Individual taxpayers can bypass the January 15 estimated payment if they file their complete 2025 Form 1040 and pay the entire balance by February 2, 2026. This extension (shifted from Jan 31 due to the weekend) allows taxpayers with organized records to retain cash for an additional two weeks.

Note: Farmers and Fishermen generally have until March 2, 2026, to file and pay if they skip estimated payments. For more details on estimated taxes, refer to IRS Publication 509.

The Feb 2 Super-Deadline: Information Reporting (W-2 & 1099)

The most operationally intensive phase of the month involves the "information return" series. The statutory deadline of January 31 moves to Monday, February 2, 2026.

Form W-2: New Requirements

Employers must file Copy A with the SSA and furnish copies to employees by February 2. Due to the OBBB, employers must now ensure precise reporting of "qualified tips" and "qualified overtime" to allow employees to claim deductions. Since standard W-2s may lack dedicated boxes for these retroactive changes, employers should utilize Box 14 or separate statements as permitted by interim guidance.

Form 1099-NEC (Nonemployee Compensation)

Form 1099-NEC is used to report payments of $600 or more to non-employees. The deadline is February 2, 2026, for both furnishing to recipients and filing with the IRS.

Form 1099-K Reversion

The reporting threshold for Third Party Settlement Organizations (TPSOs) like PayPal and Venmo has retroactively reverted to pre-ARPA levels. For the 2025 tax year filed in January 2026, Form 1099-K is required only if the payee receives over $20,000 in gross payments AND has more than 200 transactions.

Payroll and Employment Tax Obligations

Reconciling quarterly and annual payroll liabilities is critical to preventing "mismatch" notices between Form W-2 and Form 941 data.

• Form 941 (Quarterly Return): Due February 2, 2026, for Q4 2025. If all deposits were made on time, the deadline extends to February 10.
• Form 940 (Annual FUTA): Due February 2, 2026. Review Schedule A for "Credit Reduction States" that may increase liability.
• Form 945 (Nonpayroll Withholding): Due February 2, 2026. This reports backup withholding on contractors who failed to provide a TIN.

Excise Taxes and Specialized Reporting

January 2026 also imposes deadlines for specific industries such as transportation, gambling, and fuel.

• Form 720 (Quarterly Excise): Due February 2, 2026. Note that IRS e-filing systems for excise tax often experience maintenance shutdowns until mid-January.
• Form 2290 (Heavy Highway Vehicle): If a vehicle (55,000 lbs+) was first used in December 2025, the return is due February 2, 2026.
• Form 8300 (Cash Payments >$10k): By January 31 (shifted to Feb 2), businesses must furnish a written statement to customers named on a Form 8300 filed during 2025.

Strategic Considerations

Navigating the "No Tax on Tips/Overtime" Transition

The retroactive nature of the OBBB legislation means W-2s issued in January 2026 cover the first year of these benefits. Employers should consider drafting a cover letter to accompany W-2s explaining where "Qualified Overtime" and "Qualified Tips" figures are located (e.g., Box 14), referencing IRS Notice 2025-69. This proactive step can reduce employee inquiries and assist in accurate personal tax filing.

State Decoupling Risks

While federal law may exempt tips or overtime, states like California and New York often do not automatically conform. Employees may receive a W-2 showing reduced federal taxable income, but the full gross income may remain taxable at the state level. Compliance communications should highlight this potential divergence.

Appendix: Comprehensive January 2026 Deadline Table