Form 4070 is gone: why 2025 tip reporting just got harder

Form 4070 is no longer available on the IRS website. For years, it lived inside Publication 1244, Employee’s Daily Record of Tips and Report to Employer. That publication is now obsolete, and with it, the familiar Form 4070.

At first glance, this may not seem like a major change. In practice, it creates a real compliance gap for the 2025 filing season and beyond. 

What changed and why it matters

Form 4070 was never filed with the IRS. Employees used it to report tips to their employer, generally by the 10th of the following month, as required under Internal Revenue Code rules. Employers then used those reported amounts for withholding and payroll reporting.

Now that the form is gone, the legal requirement has not changed. Employees must still report tips. Employers must still account for them. What has changed is the standard recordkeeping tool. That creates uncertainty. Without a uniform IRS form, taxpayers and preparers must rely on “similar statements or records” to meet the same requirement. 

Why is this a 2025 problem

This change comes at the same time new deductions for qualified tips are taking effect for tax years 2025 through 2028. While the headlines suggest a simple benefit, the reporting system has not caught up. The IRS has confirmed that 2025 Forms W-2 and other information returns were not redesigned to separately show qualified tips. That means practitioners will not always see a clean number on year-end forms.

Instead, they may need to reconstruct tip income using multiple sources:

• Form W-2, Box 7 (allocated tips, if applicable) 
• Employer records or statements 
• Employee tip logs or spreadsheets (replacing Form 4070) 
• Additional unreported tips reported on Form 4137, Social Security and Medicare Tax on Unreported Tip Income 

Without Form 4070, one of the most reliable contemporaneous records is gone. That increases the burden on taxpayers to maintain consistent documentation.

What replaces Form 4070

The IRS does not require a specific format. Employees can use any record that captures:

➔Total tips received 

➔Dates tips were earned 

➔Amounts reported to the employer  

In practice, this could be a spreadsheet, a notebook or payroll app records. The key is consistency and accuracy. For preparers, this means asking better questions. If a client works in a tipped occupation, do not assume the W-2 tells the full story.

Where Form 4137 still fits 

If an employee does not report all tips to the employer, they must still report those amounts on Form 4137. This has not changed. Form 4137 ensures Social Security and Medicare taxes are paid on unreported tips. It also feeds into total income, which may affect any tip-related deduction.

This is where missing Form 4070 records can create problems. If there is no clear monthly reporting trail, it becomes harder to distinguish between reported and unreported tips. 

The employer side, §3121(q) 

The underlying payroll framework is still intact. Under §3121(q), employers are responsible for their share of Social Security and Medicare tax on tips that employees report to them.

However, if employees do not report tips, the employer is generally not liable for the employer share until the IRS issues a notice and demand. This reinforces why tip reporting still matters, even without Form 4070. The system depends on timely, accurate reporting from employees to employers.

What tax professionals should do now

For 2025 returns, the biggest risk is incomplete or inconsistent records. Practitioners should advise clients early to keep detailed tip logs, even without an official IRS form.

Ask clients to bring:

• Pay stubs and employer summaries 
• Personal tip records (monthly or daily) 
• Any written reports submitted to employers 
• Documentation supporting unreported tips 

The goal is to build a defensible number when the forms do not provide one. 

The bottom line 

Form 4070 may be gone, but the rules it supported are still very much in place. Tip reporting did not go away. It simply lost its standard form.

For this tax season and the next, that means more reconstruction, more documentation, and more judgment calls for preparers. The takeaway is simple: when the form disappears, the responsibility does not. Practitioners who understand the old framework will be best positioned to navigate the new one.