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IRS Publication 15: supplemental wages, 22% & 37%

Employers withhold federal tax on bonuses and RSU vests at a flat 22% on the first $1,000,000 of supplemental wages paid in a calendar year, then 37% on every dollar above that. The threshold is per-employee per-employer per-year, not per-payment. Multi-employer mid-year switches reset the counter, which can create an under-withholding gap. Rule: Treas. Reg. §31.3402(g)-1; IRS Pub 15-T.

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Tax year 2026 · Last updated June 9, 2026

IRS Publication 15-T defines a "supplemental wage" as compensation paid in addition to regular wages — most commonly bonuses, commissions, severance, accumulated leave payouts, and RSU vests. The federal withholding rule on supplemental wages is straightforward in shape: 22% flat, until you cross $1M in a year, then 37%. The threshold mechanics trip people up — especially anyone with multiple employers, mid-year job changes, or large vests near year-end.

The two rates

The flat supplemental-withholding rates
YTD supplemental wages (per employer)Federal withholding
First $1,000,00022%
Every dollar above $1M37%

These are flat withholding rates, not your tax rate.

The 37% mandatory rate matches the top federal bracket — coincidentally, since the rates were last updated in the 2017 Tax Cuts and Jobs Act.

The 22% rate is a one-size-fits-all default that under-withholds for anyone above the 22% bracket (which is most senior tech workers).

The threshold is per-employer, per-year

If you change jobs mid-year, both employers reset the $1M counter independently. 8M in supplemental wages — say, $900k from each of two employers — with $0 withheld at the 37% rate.

The IRS does not communicate YTD supplemental wage history between employers. 8M). The shortfall: ~$270k at filing.

This mid-year job-change trap is common for senior tech workers leaving one company for another with similar comp.

Every job change with $500k+ of supplemental wages already paid earlier in the year should prompt a quarterly estimated tax payment or a Form W-4 line 4(c) top-up at the new employer.

How a vest that crosses the threshold gets withheld

If your YTD supplemental wages going into a vest are $800k and the vest is $400k, the math:

$800k YTD supplemental, then a $400k vest
Slice of the vestRateWithheld
First $200k (brings YTD to $1M)22%$44,000
Next $200k (above $1M)37%$74,000
Total on the $400k vest29.5% blended$118,000

5% blended withholding is still well below the actual 37% marginal rate plus state and Medicare layers — so even crossing into the 37% mandatory rate does not eliminate the shortfall.

The all-in real marginal can hit 50%+ at the top.

Why 37% is still not enough at the very top

Once your total taxable income passes the top federal bracket threshold ($626,350 single, $751,600 MFJ in 2025; $640,600 single, $768,700 MFJ in 2026), every additional dollar of ordinary income is taxed at:

A top NYC earner’s true marginal rate
LayerRate
Federal37%
Additional Medicare (§3101(b)(2))0.9%
New York state10.9%
NYC local3.876%
True marginal~51.7%

So the 37% supplemental withholding still leaves a ~14-point gap to the real marginal rate at the very top. Other high-tax states stack similarly: California up to 14.3% (with the mental-health surcharge), New Jersey ~13%, DC ~10.75%. Additional Medicare applies above $200k single / $250k joint.

Worked example — mid-year job change

You leave Employer A in June with $600k of YTD supplemental wages already paid (large pre-IPO RSU lockup vest in March).

You start at Employer B in July with a $300k signing bonus paid that month.

Two employers · $900k supplemental · one year
Withheld (22%)$198k
Actually owed (37%)$333k
April shortfall$135k
Each employer resets the $1M counter from $0
EmployerSupplemental paidWithheld
A (Jan–Jun)$600,000$132,000 (22%)
B (Jul onward)$300,000$66,000 (22%)
Combined$900,000$198,000 (22% blended)

At your real 37% marginal rate (total income is well above the ~$626k top-bracket threshold), the actual federal tax is $900,000 × 37% = $333,000 — a $135,000 shortfall at filing.

The IRS does not require either employer to track the other's supplemental wages.

The reconciliation happens entirely at your 1040 — and any underpayment triggers the IRC §6654 penalty unless you covered the gap via Form W-4 line 4(c) extra withholding or a quarterly estimated tax payment before December 31.

Put in your own vest and bracket — see the exact 22%-vs-real-rate gap

How to fix the under-withholding

  1. Top up W-4 line 4(c) — extra withholding per paycheck. The IRS treats it as paid evenly all year (§6654(g)(1)), so it retroactively cures the gap. The cleanest fix.
  2. Quarterly estimate at irs.gov/payments — counts only from the day you pay, so use it if you missed the W-4 window.
  3. Both, for a big shortfall (>$100k): W-4 top-up + a Q4 estimate.

Aggregate method as an alternative

Two ways your employer can withhold on a bonus/vest
MethodWhat it withholdsWho uses it
Flat rate (default)22% (37% over $1M YTD)Most companies — simpler
AggregateYour effective rate (~28–32% for high earners)A minority

When to talk to a CPA

  • Switched jobs mid-year with $500k+ in bonuses/vests — the 22% counter resets per employer.
  • Double-trigger vests at an IPO — years of income compress into one, often crossing $1M.
  • First time crossing $1M YTD — withholding jumps 22% → 37%; plan the cash flow.
  • Moved states mid-year — state sourcing stacks on the federal gap.

The takeaway

The 22%/37% supplemental withholding rule is a per-employer, per-year mechanic — not a true marginal-rate calculation. The 22% rate under-withholds for anyone above the 22% federal bracket.

The 37% rate at the very top still leaves a gap to actual marginal rate when state, Additional Medicare, and local taxes stack.

The single most expensive trap is the multi-employer mid-year switch where each employer's $1M threshold resets independently.

Cover the shortfall before December 31 via Form W-4 line 4(c) or a quarterly estimated payment to avoid IRC §6654 underpayment penalties.

Sources & citations

IRC §3402(g) (supplemental wage withholding rule); Treas. Reg. §31.3402(g)-1 (flat-rate method); Treas. Reg. §31.3402(g)-1(a)(2) (aggregate method); Treas. Reg. §31.3402(g)-1(b) ($1M threshold mechanics); IRC §6654 (underpayment-of-estimated-tax penalty); IRC §6654(g)(1) (withholding deemed paid evenly across the year); IRC §3101(b)(2) (Additional Medicare Tax 0.9%); IRS Publication 15-T (Federal Income Tax Withholding Methods, 2026); IRS Form W-4 instructions.

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