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When is a Meal not a Meal for Tax Purposes?

We’re not debating calories or whether that charcuterie board counts as an appetizer or dinner.  We're talking about the IRS tightening the rules for deductible meals. 

Starting January 1, 2026, some winery meals that have historically been deductible will become completely nondeductible.

  • Same harvest crew.
  • Same pizza.
  • Different tax result.

Here is what changes and what does not.

1. Harvest Meals on Winery Premises

Zero Deduction Beginning in 2026

If you provide meals at the winery so employees can keep working, those meals will no longer be deductible starting in 2026.

That includes:

  • Crush pad dinners
  • Bottling day lunches
  • Late night production meals served on site

For years these were deductible. Beginning in 2026, they are not.

If harvest meals are a routine part of your operations, this is worth budgeting for now.

2. Occasional Overtime Meal Reimbursements

Possibly Still 50 Percent Deductible

If an employee unexpectedly works late and you reimburse them for dinner, that may still qualify for a partial deduction.

But it must be:

  • Occasional, not routine
  • Truly overtime beyond normal hours
  • Not a fixed allowance

If Friday night pizza is standard policy during harvest, that likely will not qualify. If a pump fails and someone stays late once in a while, that is different. Documentation matters.

3. Hosted Wine Dinners

Often Not a Meal Deduction at All

This is where wineries frequently get confused.

If you host a winemaker dinner and:

  • The restaurant charges guests
  • You provide the wine
  • You send a winemaker to speak

You are not deducting a meal.

You are deducting:

  • The cost of the wine
  • Travel
  • Marketing expenses

That is a marketing expense, not a meal limitation issue.

Many wineries mistakenly limit this to 50 percent when they do not need to.

4. When You Pay for the Dinner

If you pick up the tab for key buyers or distributors, that is a business meal.

That remains partially deductible, generally at 50 percent.

The difference is simple:

  • If you are pouring wine and someone else is serving dinner, you likely do not have a meal deduction issue.
  • If you are paying for dinner, you do.

The Bottom Line for 2026

Wineries now have four categories:

  • Production meals on premises
    No deduction beginning in 2026.
  • Occasional overtime reimbursements
    Possibly partially deductible.
  • Marketing events where you provide wine
    Usually not subject to meal limits.
  • Dinners you pay for
    Partially deductible.

The credit card description might just say “Restaurant.”

The tax result depends on why you were there and who paid. Classify it correctly now, or you may find yourself picking up the tab for the IRS later.

As always, consult your tax advisor for questions about specific applications of these rules, beginning January 1, 2026.