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Molly Hansen

Are vendor gifts to employees taxable? IRS guidelines for gift cards and prizes

Hey tax folks! Our purchasing department is getting flooded with vendor gifts for our staff during the holiday season, and I'm trying to figure out the tax implications before we distribute anything. Several of our regular suppliers have dropped off gift cards ($50 values) and some home items like small appliances with notes saying "Please share these with your team for the holidays!" Since the vendors are providing these items and we're just handling the distribution, I'm wondering if these are still considered taxable to our employees? Also related question about our upcoming company events: We're planning two employee raffles this year - one for the holidays and another for our summer picnic. For the gift cards in the raffle, we already know those are taxable and have a process to handle that. But I'm struggling with the other prizes. I've read through the IRS publications on de minimis fringe benefits but can't find a specific dollar threshold. I saw an IRS publication from December 2020 indicating that $100 fair market value isn't considered de minimis, which helps somewhat. But what about items valued at $75 or $85? Where's the cutoff? For our raffle prizes, we have: - Chocolate and fruit baskets (which seem clearly de minimis from the examples) - Wireless speakers ($55) - Air fryers ($90-$110) - Smart TVs ($350-$475) I'm pretty sure the TVs are taxable, but I'm less clear on the mid-range items. We could just make everything except the food baskets taxable to be safe, but wanted to check if anyone has clearer guidance on where to draw the line. Thanks!

There are actually two separate issues here that need different treatment: For the vendor gifts, these are still considered taxable income to your employees even though they come from vendors. The IRS views this as the vendors providing compensation to your employees through your company. Since you're distributing the items, your company is responsible for reporting this as compensation. The fact that your company didn't purchase the items doesn't change the tax treatment. For the raffle prizes and de minimis benefits question, you're right that there's no specific dollar threshold in the regulations. The $100 guideline you found is helpful but not an official bright-line rule. The IRS generally considers the frequency and value together. One-time gifts of "low value" can qualify as de minimis, but what's considered "low value" depends on circumstances. Generally, food baskets, small gift baskets, company logo merchandise, and very occasional tickets to events can qualify as de minimis. More substantial items like electronics (speakers, air fryers, TVs) will almost certainly be taxable regardless of value because they have a longer useful life and significant value.

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Thanks for clarifying! So basically all those vendor gift cards and appliances need to be treated as taxable income even though we're just the middleman. That's going to be a pain to track, but it makes sense. For the raffle prizes, is there any rule of thumb for what "low value" typically means in practice? I've seen some companies use $25 as their cutoff, others use $75. Just trying to figure out if there's a generally accepted number in the industry.

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The most common rule of thumb I've seen companies use is around $25-$50 for de minimis items, though this isn't an official IRS threshold. It's more about the nature of the item than the exact dollar amount. Items that are consumed quickly (food, flowers) or have minimal resale value tend to be safer as de minimis regardless of cost. For electronic items, even inexpensive ones, they generally don't qualify as de minimis because they have lasting value and utility beyond the workplace. So those speakers, even at $55, would likely be taxable because they're not consumable and have ongoing value to the employee.

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Does it actually tell you specific dollar thresholds for what counts as de minimis? I've been looking everywhere for that info. Our company has been using $25 as the cutoff, but I think that's unnecessarily conservative.

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Corporate tax specialist here. I've dealt with this issue for multiple clients. Here's what you need to know: 1) All vendor gifts to employees ARE taxable income. The source doesn't matter - what matters is that the employee is receiving something of value because of their employment relationship. 2) For de minimis fringe benefits, while there's no official dollar amount in the regulations, most tax professionals use $25-$75 as a practical guideline based on various IRS examples and cases. 3) However, the nature of the item matters more than the exact value. Food items, flowers, occasional event tickets tend to qualify as de minimis more easily than durable goods like electronics. 4) For your raffle, the element of chance doesn't change the tax treatment. If an employee wins a taxable prize, it's still taxable even if they had a small chance of winning. My advice: track everything over $25 that isn't a consumable item. Better to be conservative than face penalties later.

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Does it matter if the raffle is open to non-employees too? We do a holiday raffle that includes employees, their families, and some community members. Does that change anything about the tax treatment?

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Great question. If the raffle is genuinely open to the public and not just employees, the tax treatment can be different. When non-employees have the same opportunity to win as employees, prizes can potentially be treated as non-compensatory. However, there are strict requirements for this. The event must be truly open to non-employees with equal opportunity to participate, not just a token few outsiders. Even then, you'd need to report prizes over $600 on Form 1099-MISC for winners, rather than as wages. For employees who win, you'd still need to evaluate whether they received the opportunity because of their employment.

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Has anyone considered just having the vendors distribute the gifts directly to employees rather than going through the company? Would that change the tax implications at all?

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Unfortunately that wouldn't change the tax treatment. The IRS would still view these as compensatory because the vendors are providing gifts to individuals specifically because they work for your company. The employment relationship is still the reason for the gift. Even direct distribution would be considered "income from third parties attributable to employment." Your company would still have reporting and withholding obligations. The only exception might be if the gift was clearly personal in nature (like if a vendor representative had a personal friendship with an employee outside of the work context).

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Thanks everyone for the detailed responses! This has been incredibly helpful. Just to summarize what I'm understanding: 1) All vendor gifts (including those $50 gift cards) need to be treated as taxable income to employees, even though we're just distributing them 2) For our raffle prizes, the food baskets are likely de minimis, but anything electronic (speakers, air fryers, TVs) should be treated as taxable regardless of value 3) The $25-$75 rule of thumb seems to be more about consumable vs. durable goods than strict dollar amounts One follow-up question: For the vendor gifts, do we need to include the fair market value in employees' W-2s, or is there a different reporting mechanism? We're talking about potentially 50+ employees receiving these gifts, so I want to make sure we handle the paperwork correctly. Also, sounds like I should probably get our legal/compliance team involved before we finalize our raffle prize structure. Better safe than sorry with the IRS!

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You've got the right understanding! For the vendor gifts, yes, you'll need to include the fair market value in employees' W-2s as taxable wages (usually in Box 1). Since these are non-cash gifts, you'll also need to handle the withholding - either deduct taxes from the employee's regular paycheck or gross up the gift value to cover the tax burden. For 50+ employees, I'd strongly recommend setting up a tracking system now to capture the fair market value of each gift and which employees received them. You'll need this documentation for year-end W-2 preparation and in case of any IRS questions. And absolutely get your legal/compliance team involved! They can help ensure you're following all the proper procedures for both the vendor gifts and the raffle structure. It's much easier to set things up correctly from the start than to fix reporting errors later.

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Just wanted to add another perspective on the vendor gift situation. We dealt with this last year when several of our suppliers started sending holiday gift boxes directly to our office for "the team." What we learned is that even if the vendors mark the gifts as "promotional items" or "marketing materials," they're still considered taxable compensation to employees if they're distributed based on employment status. The IRS doesn't care about the vendor's intent - they care about why the employee received the benefit. One thing that helped us was establishing a clear policy upfront: we now require vendors to provide the fair market value of any gifts they want us to distribute to employees, and we include a standard notice that explains the tax implications to recipients. This way employees aren't surprised when they see the additional income on their W-2s. For your raffle question, I'd also consider the administrative burden. Even if some mid-range items might technically qualify as de minimis, the documentation and decision-making process for each prize category can be more work than just treating everything over $25 as taxable. Sometimes the "safe" approach is also the simpler approach from an HR/payroll perspective.

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This is really helpful advice about establishing a clear policy upfront! I'm curious - when you require vendors to provide fair market values, do you accept their stated values at face value, or do you verify them somehow? I'm wondering about situations where vendors might understate values to make the gifts seem less burdensome tax-wise. Also, regarding the administrative burden point - that's exactly what I'm wrestling with. It sounds like treating everything non-consumable over $25 as taxable might be the most practical approach, even if we might be able to argue that some items qualify as de minimis. The time spent analyzing each item probably isn't worth the potential savings. Did you run into any employee pushback when people saw the additional income on their W-2s? I'm trying to anticipate how to communicate this properly so people understand they're not actually being "charged" for gifts they received.

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