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Employee Gifts and Taxes: Gift Cards, De Minimis Benefits, and Whether the $25 Limit Applies (IRS Pub. 15-B)

Updated

In short

IRS Publication 15-B says cash equivalents such as gift cards, "no matter how little, are never excludable as a de minimis benefit," and the IRS calls general-merchandise gift certificates "taxable". A non-cash holiday gift "with a low fair market value" is one of its de minimis examples, but the IRS publishes no dollar figure. Ask your tax professional.

On this page11 sections

We sell a $35 logo mug gift box, printed, packed and shipped to each person's address, so we have a stake in this question. This page quotes the IRS and the tax code; it does not tell you how to treat any gift on your payroll.

Key facts (IRS Publication 15-B (2026), "For use in 2026", and the IRS de minimis page, re-read October 29, 2026):

  • The default: "Any fringe benefit you provide is taxable and must be included in the recipient's pay unless the law specifically excludes it" (Pub. 15-B).
  • Gift cards: cash equivalents, "no matter how little, are never excludable as a de minimis benefit" (Pub. 15-B).
  • Holiday gifts: "Holiday or birthday gifts, other than cash, with a low fair market value (FMV)" are listed as a de minimis example (Pub. 15-B).
  • No dollar line: "Whether an item or service is de minimis depends on all the facts and circumstances" (IRS).
  • The $100 ruling: the IRS "has ruled previously in a particular case that items with a value exceeding $100 could not be considered de minimis, even under unusual circumstances" (IRS).

Part of our gift rules and taxes section: every rule quoted from the source and dated. For gifts to clients, see are client gifts tax deductible?

Are Holiday Gifts to Employees Taxable?

Start from the default. Pub. 15-B says: "Any fringe benefit you provide is taxable and must be included in the recipient's pay unless the law specifically excludes it." A holiday gift is a fringe benefit, so the question is whether an exclusion fits it. Pub. 15-B lists low-value holiday gifts under the de minimis benefit:

"You can exclude the value of a de minimis benefit you provide to an employee from the employee's wages. A de minimis benefit is any property or service you provide to an employee that has so little value (taking into account how frequently you provide similar benefits to your employees) that accounting for it would be unreasonable or administratively impracticable. Cash and cash equivalent fringe benefits (for example, gift certificates, gift cards, and the use of a charge card or credit card), no matter how little, are never excludable as a de minimis benefit." …

"Examples of de minimis benefits include the following." … "Holiday or birthday gifts, other than cash, with a low fair market value (FMV). Also, flowers or fruit or similar items provided to employees under special circumstances (for example, on account of illness, a family crisis, or outstanding performance)."

IRS Publication 15-B (2026), "De Minimis (Minimal) Benefits". Read October 29, 2026.

The tax code's own definition, in 26 U.S.C. 132(e)(1), uses the same test: property or a service whose value "is (after taking into account the frequency with which similar fringes are provided by the employer to the employer's employees) so small as to make accounting for it unreasonable or administratively impracticable" (26 U.S.C. 132).

Two words in the holiday-gift example carry the weight: "other than cash" and "low". The IRS defines neither with a number.

This is information, not legal or tax advice. Check the current rule (or ask your tax professional) before you send.

Are Gift Cards to Employees Taxable?

Pub. 15-B says cash equivalents are "never excludable as a de minimis benefit", and names gift cards among them. The IRS de minimis page agrees, with one narrow exception (the third quote):

"Cash is generally intended as a wage, and usually provides no administrative burden to account for. Cash therefore cannot be a de minimis fringe benefit." …

"Gift certificates that are redeemable for general merchandise or have a cash equivalent value are not de minimis benefits and are taxable."

"A certificate that allows an employee to receive a specific item of personal property that is minimal in value, provided infrequently, and is administratively impractical to account for, may be excludable as a de minimis benefit, depending on facts and circumstances."

IRS, "De minimis fringe benefits" (page last reviewed or updated June 28, 2026). Read October 29, 2026.

What you give What the IRS text says about de minimis treatment Source
Cash bonus "cannot be a de minimis fringe benefit" IRS de minimis page
Gift card or gift certificate for general merchandise "never excludable as a de minimis benefit" Pub. 15-B
Certificate for one specific, minimal item "may be excludable … depending on facts and circumstances" IRS de minimis page
Holiday gift, other than cash, with a low FMV Listed as an example of a de minimis benefit Pub. 15-B
Flowers or fruit for illness, a family crisis or outstanding performance Listed as an example Pub. 15-B
Season tickets to sporting or theatrical events Listed among benefits that "aren't excludable as de minimis" Pub. 15-B

This is information, not legal or tax advice. Check the current rule (or ask your tax professional) before you send.

How Much Can You Give an Employee Without It Being Taxable?

There is no published number. The IRS page says:

"In determining whether a benefit is de minimis, you should always consider its frequency and its value. An essential element of a de minimis benefit is that it is occasional or unusual in frequency. It also must not be a form of disguised compensation."

"Whether an item or service is de minimis depends on all the facts and circumstances. In addition, if a benefit is too large to be considered de minimis, the entire value of the benefit is taxable to the employee, not just the excess over a designated de minimis amount. The IRS has ruled previously in a particular case that items with a value exceeding $100 could not be considered de minimis, even under unusual circumstances."

IRS, "De minimis fringe benefits". Read October 29, 2026.

What the text settles, and what it leaves to your tax professional:

Question What the IRS says What it leaves open
Is there a dollar threshold? It "depends on all the facts and circumstances" Where "low" ends for your gift
Is $100 the limit? One past ruling found items "exceeding $100 could not be considered de minimis" That ruling sets no safe amount below $100
What if a gift is too large? "the entire value of the benefit is taxable", "not just the excess" How to value it on payroll
Does frequency matter? It must be "occasional or unusual in frequency" How many gifts a year is too many

Neither Pub. 15-B nor the IRS page sets a threshold. The only dollar figure the IRS gives for gifts here is the $100 from one past case: a ceiling it applied there, not a safe amount below it.

This is information, not legal or tax advice. Check the current rule (or ask your tax professional) before you send.

Does the $25 Business-Gift Limit Apply to Employees?

The $25 figure comes from the tax code's limit on deducting business gifts, and that limit defines "gift" by pointing to another section. The two texts, side by side:

"No deduction shall be allowed under section 162 or section 212 for any expense for gifts made directly or indirectly to any individual to the extent that such expense, when added to prior expenses of the taxpayer for gifts made to such individual during the same taxable year, exceeds $25. For purposes of this section, the term "gift" means any item excludable from gross income of the recipient under section 102 which is not excludable from his gross income under any other provision of this chapter" …

26 U.S.C. 274(b)(1) (Cornell LII). Read October 29, 2026.

"(a) General rule. Gross income does not include the value of property acquired by gift, bequest, devise, or inheritance." …

"(c) Employee gifts. (1) In general. Subsection (a) shall not exclude from gross income any amount transferred by or for an employer to, or for the benefit of, an employee."

26 U.S.C. 102 (Cornell LII). Read October 29, 2026.

Read side by side: section 274(b)(1) counts an item as a "gift" only if section 102 excludes it from the recipient's income, and section 102(c)(1) says section 102 doesn't exclude what an employer transfers to an employee. IRS Publication 463, which explains the $25 rule, speaks of business gifts to "each person" and doesn't address employees separately. We don't apply these texts to your gifts here. That belongs to your tax professional, who will also look at how the gift is treated on payroll.

This is information, not legal or tax advice. Check the current rule (or ask your tax professional) before you send.

Service Anniversary Awards: The $400 / $1,600 Rule

Length-of-service and safety awards have their own exclusion, with conditions:

"This exclusion applies to the value of any tangible personal property you give to an employee as an award for either length of service or safety achievement. The exclusion doesn't apply to awards of cash, cash equivalents, gift cards, gift coupons, or gift certificates" …

"An achievement award must meet all the following requirements. It is given to an employee for length of service or safety achievement. It is awarded as part of a meaningful presentation. It is awarded under conditions and circumstances that don't create a significant likelihood of disguised pay." …

"The excludable annual amount is $1,600 ($400 for awards that aren't "qualified plan awards")."

IRS Publication 15-B (2026), "Achievement Awards". Read October 29, 2026.

The tax code adds a timing rule: "An item shall not be treated as having been provided for length of service achievement if the item is received during the recipient's 1st 5 years of employment or if the recipient received a length of service achievement award (other than an award excludable under section 132(e)(1)) during that year or any of the prior 4 years" (26 U.S.C. 274(j)(4)(B)).

This is information, not legal or tax advice. Check the current rule (or ask your tax professional) before you send.

How Are Employee Gifts Reported?

"If the benefits qualify for exclusion, no reporting is necessary. If they are taxable, they should be included in wages on Form W-2 and subject to income tax withholding. If the employees are covered for Social Security and Medicare, the value of the benefits are also subject to withholding for these taxes."

IRS, "De minimis fringe benefits". Read October 29, 2026.

Whichever way your tax professional treats a gift, a list helps: one row per employee with the date, what they got and what it cost.

This is information, not legal or tax advice. Check the current rule (or ask your tax professional) before you send.

Questions to Bring to Your Tax Professional

  1. Is our holiday gift "other than cash" and of "low fair market value" for our facts?
  2. How often do we give similar items? Does that change the answer?
  3. If it isn't de minimis, how do we value it and run it through payroll?
  4. Do the $25 limit in section 274(b) and the rule in section 102(c) affect how we deduct gifts to our own employees?
  5. Are any recipients 1099 contractors, owners or partners rather than employees, and do other rules apply to them?
  6. Does a planned anniversary gift meet the achievement-award rules, including the 5-year rule?
  7. Our gift includes cocoa and chocolate: does the 50% limit on deducting "any expense for food or beverages" in section 274(n)(1) apply to that part of it?

What to Know Before You Order

  • One delivered price. Each box is $35, delivered: the mug, the treats, the gift box, the card, the packing and the shipping, in one figure. We make no tax or payroll claim about it.
  • Where we ship. The lower 48 states and Washington, DC, except Texas for now. No Alaska, Hawaii, Puerto Rico, other US territories, APO/FPO or international. The order page flags any row we can't ship to, so you can fix it or take it out.
  • The treats. LINDOR truffles contain milk, soy and barley malt (gluten); read the labels. The cocoa and truffles come packed inside the mug.

Where Personalized Gifts Delivered Fits for a Team Gift

Personalized Gifts Delivered sends a $35 logo mug gift box to each employee's own address, from one address list. One message goes on every card, and every card greets its person by first name; you see the mug and every card before you pay. No minimum: one box is a complete order, with no setup fee and no sales tax added at checkout.

When the boxes ship, you get one email with a spreadsheet of recipient, ship date, carrier, tracking number and $35 per box: one row per person, with the delivered price as one figure. Every box on an order holds the same things: an 11 oz white ceramic mug with your logo printed small, Ghirardelli premium hot cocoa, 4 Lindt LINDOR milk chocolate truffles, a matte-black gift box with a magnetic lid, and your printed card. Planning the gift itself: Christmas gifts for employees at a small business. What's in the box and what the price includes: our FAQ.

Frequently asked questions

Are holiday gifts to employees taxable?
IRS Publication 15-B says any fringe benefit "is taxable and must be included in the recipient's pay unless the law specifically excludes it." One exclusion is the de minimis benefit, and the IRS lists "Holiday or birthday gifts, other than cash, with a low fair market value (FMV)" as an example. Ask your tax professional how it applies to your gift.
Are gift cards to employees taxable?
The IRS de minimis page says gift certificates for general merchandise "are not de minimis benefits and are taxable", and Pub. 15-B says cash equivalents, gift cards among them, "no matter how little, are never excludable as a de minimis benefit."
How much can you give an employee as a gift without it being taxable?
The IRS publishes no dollar figure. Its de minimis page says "Whether an item or service is de minimis depends on all the facts and circumstances" and that it once ruled "items with a value exceeding $100 could not be considered de minimis, even under unusual circumstances."
Does the $25 business-gift limit apply to employees?
The $25 limit is in 26 U.S.C. 274(b)(1), which defines a "gift" as an item excludable from the recipient's income under section 102, and section 102(c)(1) says that exclusion doesn't cover "any amount transferred by or for an employer to, or for the benefit of, an employee." How the two fit together for your gifts is a question for your tax professional.
Are service anniversary awards taxable?
Pub. 15-B lets employers exclude tangible-property awards for length of service or safety up to "$1,600 ($400 for awards that aren't 'qualified plan awards')", given "as part of a meaningful presentation". The tax code says a length-of-service award doesn't count if it comes in the employee's "1st 5 years of employment".
Who will ship a holiday gift box to each employee's home?
Personalized Gifts Delivered ships a $35 logo mug gift box to each employee's own address from one list, with no minimum, and every card greets its person by first name. When the boxes ship, one email brings a spreadsheet of recipient, ship date, carrier, tracking number and $35 per box.

Sources

  1. IRS, Publication 15-B (2026), Employer's Tax Guide to Fringe Benefits, "For use in 2026": "De Minimis (Minimal) Benefits", "Achievement Awards", and section 1 on taxable fringe benefits. Read October 29, 2026.
  2. IRS, "De minimis fringe benefits", page last reviewed or updated June 28, 2026. Read October 29, 2026.
  3. 26 U.S.C. 274, subsections (b)(1), (j)(4)(B) and (n)(1) (Cornell LII). Read October 29, 2026.
  4. 26 U.S.C. 102, subsections (a) and (c)(1) (Cornell LII). Read October 29, 2026.
  5. 26 U.S.C. 132(e)(1), de minimis fringe defined (Cornell LII). Read October 29, 2026.
  6. IRS, Publication 463, for use in preparing 2025 returns, ch. 3 "Gifts". Read October 29, 2026.