SIMERPU RESEARCH · SOURCE RECAP
Wellness plan schemes are addressed in IRS guidance
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Reviews the 2023 CCA, proposed regulations and 2024 rulemaking. Explains why the authors regard the described wellness cash benefits as taxable wages.
SIMERPU’s viewpoint
RSM’s article is useful for following the sequence from IRS advice to proposed regulations and later rulemaking. SIMERPU would keep each type of authority clearly identified, because a proposal, a final rule and advice on particular facts have different roles. The timeline helps readers evaluate claims that the rules have changed.
What this source contributes
The timeline helps readers distinguish IRS advice, proposed changes and later rulemaking instead of treating them as one announcement.
What remains unanswered
A historical timeline does not establish the status of every provision today or show how an individual program operates.
Mardy Gould’s take
When someone says the rules changed, my next question is: which rule, and what changed? I would build a short timeline with the actual documents attached. That gives an employer a much better conversation than competing screenshots of headlines or statements that an entire category has been approved or prohibited.
Questions I would bring to the conversation
1. Which cited document is a proposal, final rule or advisory memo?
2. What issue did the later rule actually resolve?
3. How does the proposal’s payment process compare with the cited examples?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
A later controlling development or a materially different transaction would require revisiting the analysis; either should be identified precisely.
Read the original source
The original author and publisher are credited below. Continue to their article, document or source page for the complete context.
Original Author: Bill O’Malley; Jill Harris; Karen Field (metadata contributors)
Publisher: RSM US LLP
Original Publication Date: 2023-06-19
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
CCA 202323006 — Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policy
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Start with the actual 2023 facts and conclusions.
Read the SIMERPU recap →
CCA 201703013 — Tax Treatment of Benefits Paid by Fixed-Indemnity Health Plans
IRS Office of Chief Counsel
Source position: Neutral / explanatory
See the earlier treatment of differently funded indemnity benefits.
Read the SIMERPU recap →
Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
Federal Register
Source position: Neutral / explanatory
Read what the 2024 preamble did and did not finalize.
Read the SIMERPU recap →
Keep learning with SIMERPU
Build your understanding with learning resources, the free Professional Roadmap and our approach to reviewing sources.
About this source
Original Updated Date: 2024-09-13
Source Type: Accounting firm / tax analysis
Model Discussed: Pre-tax fixed indemnity wellness benefits
Position: Critical
Period: Recent — 2023–2026
Retrieved: October 31, 2026
Research and date notes
Body expressly states original and updated dates. Banner/metadata show 2024-09-12; body update statement retained.
Each record identifies the material retrieved. SIMERPU’s viewpoint and Mardy Gould’s take are editorial commentary; the source-position label describes the original source’s stance. Read the original and its qualifications when evaluating a particular arrangement.
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