Employers must take into account the wage-hour requirements and restrictions of all jurisdictions in which they employ tipped workers, as well as how these provisions interact with the FLSA's requirements.
Employers who are currently relying upon a "highly compensated" version of the FLSA's white-collar exemptions should carefully consider the 2016/2017 transitional implications of the higher "total annual compensation" dollar amount that goes into effect on December 1.
Congress has responded to the U.S. Labor Department's impending revisions of its FLSA Section 13(a)(1) exemption definitions by introducing nullifying legislation.
The U.S. Labor Department has released Administrator Interpretation No. 2016-1, dealing with concepts of "joint employment" under the Fair Labor Standards Act and the Migrant and Seasonal Agricultural Worker Protection Act.