On March 25, 2025, President Trump signed an Executive Order to modernize how the government handles money—switching from paper-based payment to electronic payment.
The Order mandates that effective September 30, 2025, the federal government will cease issuing paper checks for any disbursements, including tax refunds. Additionally, payments made to the federal government must also be processed electronically. While it does state that exceptions may be made for people without banking or electronic payment access – it is yet to be seen how these exceptions will apply.
The order outlines several reasons for the change including:
This change is especially relevant for companies with globally mobile and tax equalized employees, many of whom have processes in place to fund tax payments and receive tax refunds directly on behalf of their employees, generally involving the use of paper checks. Many of these companies will need to update their policies and procedures for tax payment and reimbursement, and communications to employees regarding maintaining US bank accounts.
Even after updating processes, further complications must be considered, including:
We’re here to help you evaluate and implement strategies in response to this policy change. Companies with globally and domestically mobile populations face unique risks and challenges within our regulatory environment. We are also available to assist with any questions about your US citizen employees working abroad, non-US employees working in the United States, as well as your domestically mobile population.
For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:
David Austin
Partner
Mike Branca
Partner
Julie Baron
Partner
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