IRS Proposes A New Acronym and a New Tip Reporting Program

The government loves a good acronym for a program, institution or act, like FATCA (Foreign Account Tax Compliance Act), TEFRA (Tax Equality and Fiscal Responsibility Act), NASA or IRS. There must be a branch of the government solely dedicated to creating acronyms and making sure the acronym is not offensive, like Seattle’s South Lake Union Trolley which I understand was quickly changed to South Lake Union Streetcar.

Some of my favorite acronyms are:

1. Liaison Officer for Recognized and Authorized Classification Societies (LORACS);
2. National Museum of American History (NMAH pronounced “enema”);
3. WikiLeaks Task Force (WTF);
4. Reporting Hospital Quality Data For Annual Payment Update (RHQDAPU pronounced rack-da-poo);
5. Reconversion Unemployment Benefits for Seamen (RUBS);
6. Uniting & Strengthening America by Providing Appropriate Tools Required to Intercept & Obstruct Terrorism (USA PATRIOT Act);
7. Title Eight Automated Paperless Office Tracking System (TEAPOTS);
8. Leaking Underground Storage Tanks program (LUST);
9. Office of the National Coordinator for Health Information Technology (ONCHIT);
10. Brewers Excise and Economic Relief Act of 2013 (BEER);
11. Captioning and Image Narration to Enhance Movie Accessibility Act (CINEMA);
12. Robo Calls Off Phones Act (Robo COP); and
13. Department On Aging (DOA).

Last week, the IRS proposed a new acronym, SITCA, which stands for Service Industry Tip Compliance Agreement program. SITCA is a voluntary tip reporting program which will be offered to employers in the service industry, other than gaming. It was proposed by the National Tip Reporting Compliance Program (NTRCP) and is intended to replace previous tip programs TRAC (Tip Reporting Alternative Commitment), TRDA (Tip Rate Determination Agreement) and EmTRAC (Employer-Designed Tip Reporting). That last acronym does not seem to fit, but that’s the name of the IRS program and the acronym by which it is known. Not surprisingly, tips, especially cash tips have a tendency to escape the tax system and the IRS has had numerous programs to try to capture and tax tips. The particulars of the proposed SITCA program can be found in IRS Notice 2023-13 .

In its announcement regarding the proposed SITCA program the IRS said, “The proposed SITCA program is designed to take advantage of advancements in point-of-sale, time and attendance systems, and electronic payment settlement methods to improve tip reporting compliance. The proposed program would also decrease taxpayer and IRS administrative burdens and provide more transparency and certainty to taxpayers. The proposed program includes several features:

• The monitoring of employer compliance based on actual annual tip revenue and charge tip data from an employer's point-of-sale system, and allowance for adjustments in tipping practices from year to year.
• Participating employers demonstrate compliance with the program requirements by submitting an annual report after the close of the calendar year, which reduces the need for compliance reviews by the IRS.
• Participating employers receive protection from liability under the rules that define tips as part of an employee's pay for calendar years in which they remain compliant with program requirements.
• Participating employers have flexibility to implement employee tip reporting policies that are best suited for their employees and their business model in accordance with the section of the tax law that requires employees to report tips to their employers.”

If you have any tax-related questions or would like to share your favorite government acronym, please feel free to contact me at jcrouch@meadowscollier.com.