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 Comment Letters

IPA Argues On-Demand Pay Tax Proposal is Unfair to Businesses

4/11/2024

 
The Innovative Payments Association (IPA) is writing to the Department of the Treasury to comment on the President's 2025 Budget Proposal regarding on-demand pay (ODP). The IPA argues that the Proposal's definition of ODP is inaccurate and that the Proposal would create a significant administrative burden for businesses. The IPA also argues that the Proposal would not have a significant impact on tax revenues.

The IPA recommends that the Treasury Department revise the Proposal to reflect a more accurate description of the current ODP marketplace and to acknowledge that the vast majority of ODP arrangements are offered by third-party providers. The IPA also recommends that the Treasury Department clarify that disbursements made via a third-party ODP provider should be excluded for tax purposes at the time of their disbursement.
​
Overall, the IPA is concerned that the Proposal would make it more difficult for businesses to offer ODP to their employees. The IPA believes that ODP is a valuable tool that can help employees manage their finances and avoid costly payday loans.
Download Comment Letter

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  • About Us
    • Our Team
    • Board of Directors
    • Members
    • Partnerships
  • News & Events
    • Newsroom
    • Events
    • Blog
    • Podcast
  • Member Resources
    • Glossaries & Reports
    • GRWG
    • Recordings
    • Government Update
    • State Legislative Tracker
    • Financial Crimes Investigators
  • Issues & Advocacy
    • Comment Letters
    • Payments Litigation
    • Current Issues >
      • Earned Wage Access
      • Fraud Prevention
      • Prepaid Rule
    • Ongoing Issues >
      • Arbitration
      • Artificial Intelligence
      • Banking as a Service
      • Brokered Deposits
      • CFPB
      • Covid Response
      • Durbin Amendment
      • FDIC & OCC
      • Privacy Legislation
      • Unclaimed Property
  • Join the IPA
    • IPA Wins
  • IPC 2026
    • Register
    • Hotel & Travel
    • Sponsorship Opportunities
    • Agenda
    • FAQ
    • 2026 Maher Award