The time for meals to celebrate Thanksgiving and the winter holiday is fast approaching, but employers best beware, there is no such thing as providing a free lunch. According to Doug Hass of Franczek Radelet, even though many will point to the increased productivity and morale a company-provided holiday meal can offer, there are legal considerations on the menu too.

“This year’s turkeys, hams and sandwiches have an additional complication that might give employers some indigestion: wage and hour laws and the hot new liability theory spurred by the IRS,” says Hass. Or was it the Grinch? Basically, Hass says the broad definition of “wages” includes the cash value of all compensation, even those things not paid in cash. So if you’re paying your employees in turkeys, there are wage and hour ramifications. Think of it as a “Thanksgiving turkey ‘bonus,’” he says.

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