On January 15, 2025, the Internal Revenue Service (IRS) published Revenue Rule 2025-4 (Rev. Rul. 2025-4), which provides direct guidance addressing the federal taxation and applicable reporting requirements for contributions and benefits paid under a state paid family and medical leave (PFML) program. This guidance is generally effective for state PFML contributions and benefits paid on or after January 1, 2025, subject to a temporary transition period for certain requirements.
This Alert is relevant for employers operating in, or with employees working in, states with mandatory PFML programs. As of the date of this Alert, this includes California, Colorado, Connecticut, Delaware, Maine, Maryland, Massachusetts, Minnesota, New Jersey, New York, Oregon, Rhode Island, Washington, and the District of Columbia.
