Employee gift cards: IRS plays Scrooge
October 30, 2008 by Bill MeltzerPosted in: Compensation, Compliance, In this week's e-newsletter, Latest News & Views, Recognition programs
Many employers try to reward employees during the holidays. But be careful:
There’s a common misbelief that the IRS considers gift cards worth $20 or less de minimus benefits and, therefore, they’re tax free. Unfortunately, that’s not true. With few exceptions, the IRS considers almost anything with cash value a taxable form of compensation.
Practically speaking, the IRS is unlikely to go after your firm or an employee over a few small-value gift cards for which you withheld no taxes. But they could, especially if your firm regularly hands out gift cards. At some firms, those $5 to $20 cards can add up to several thousand dollars worth of unpaid taxes in a few years. Each $15 gift card would typically require about $5.55 withheld.
To be safe, you can use gift cards sparingly and pay the tax for the recipient. Or else you can educate folks proactively that Uncle Sam requires you to take out for taxes.
Read the fine print
Gift cards can be money-wasters or or morale-killers if employees have a bad experience trying to redeem them. Read the fine-print before you buy. Three common pitfalls to watch:
- expiration dates. Some retailers offer cards that last forever. But many have expiration dates, rendering the cards worthless after a period of time
- dormancy fees. A $50 card can end up worth only $40 at stores that deduct “dormancy fees” after a certain period of time, and
- redemption fees. Some stores charge a fee for redeeming cards that can be used in multiple locations.
The good news: There are some good deals out there. Employer use of gift cards has doubled since 2001, and related sales bring in $20 billion a year to retailers. With such fierce competition, it pays to shop around.

November 6th, 2008 at 2:15 pm
I used to handle imputed income for a large corporation. The guidance given was the IRS considered any gift under $25 as “de minimus”. However, you must track the gift cards given to employees and if the total was greater than $50 we would consider that “imputed income” to the employee and charge tax
November 14th, 2008 at 9:28 am
That is an old rule interpretation, the IRS has specifically ruled that gift cards of any value are taxable income now, there is no de minimus exception. IF you search the web make sure you look for recent articles