Rethinking Meals & Entertainment Deductions

Rethinking Meals & Entertainment Deductions

Written by Hawkins Ash

September 25, 2025

The One Big Beautiful Bill Act (OBBBA) brings several important updates to how businesses can deduct meals and entertainment (M&E) expenses. While some rules remain the same, others will change starting in 2026. Understanding what’s deductible—and what’s not—can help you protect valuable tax savings.

Entertainment Is Still Out, Meals Are Still Limited

  • Entertainment expenses remain nondeductible under Sec. 274.
  • Business meals may still be 50% deductible if:
    • They’re not lavish or extravagant
    • An employee is present
    • They serve a valid business purpose
    • They’re separately stated from entertainment costs

OBBBA keeps these rules intact but adds new timing-based restrictions.

Employer-Provided Meals: Changes Coming Soon

Through 2025

  • Employer-provided meals remain 50% deductible if they meet Sec. 119 requirements.
  • Meals at employer-operated eating facilities are also deductible through the end of 2025.
  • Restaurants, caterers, and similar businesses may continue deducting meals provided to employees, generally at the 50% limit.

Starting in 2026

  • Meals at employer-operated eating facilities become nondeductible.
  • Meals provided for the convenience of the employer also become nondeductible.
  • Exceptions remain for:
    • Food and beverage operations (restaurants, catering)
    • Fishing vessels and certain fish processors

Where 100% Deductions Still Apply

Some meals can still qualify for full deductibility, including:

  • Meals treated as employee compensation
  • Recreational or social events for employees (holiday parties, company picnics)
  • Meals provided to the public (e.g., marketing or promotional events)
  • Meals sold to customers
  • Certain reimbursed expenses

Documentation Remains Essential

Even as deductibility changes, substantiation requirements stay the same. You’ll need records for:

  • Amount
  • Date and location
  • Purpose of the meal
  • Names or business relationships of attendees

Planning Tips for 2025–2026

  • Segregate costs between employee meals and customer-facing expenses.
  • Prepare for the phaseout of deductions on employer-provided meals.
  • Track carefully if you operate in foodservice or fishing industries where carve-outs apply.
  • Consider setting up different meals expense accounts in your general ledger to track the different types of meals to help track internally and help come tax time. 
  • Consider compensation strategies that preserve deductions.
  • Review policies now to avoid surprise disallowances in 2026.

Bottom Line

OBBBA doesn’t change everything, but it does accelerate the phaseout of employer-provided meal deductions. The impact begins in 2026, so planning ahead now can help you preserve tax benefits. Businesses in industries with exceptions—like restaurants, caterers, and fisheries—should pay close attention to how expenses are tracked and categorized.

 

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Hawkins Ash
A regional, full-service public accounting firm
Hawkins Ash CPAs is a regional, full-service public accounting firm. Since 1956, we’ve provided consistent, thoughtful, and difference-making audit, accounting, tax, and consulting services to clients in Wisconsin, Minnesota, and across the United States. We are a growing firm with currently five offices in Wisconsin and three offices in Minnesota. Firm wide, we have 125 professionals and 14 partners. Our professionals work with various privately held, governmental, nonprofit, housing authority, and credit union clients.

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