SIMERPU RESEARCH · SOURCE RECAP

IRS Chief Counsel Advice Says Wellness Indemnity Payments Are Taxable If No Unreimbursed Medical Expenses Related to the Payment

SIMERPU recap and commentary: Mardy Gould

Opened — main text retrieved

Quick recap

Analyzes the CCA’s $1,200 premium / $1,000 payment facts, income exclusion rules and employment taxes; connects the memo to earlier IRS advice.

SIMERPU’s viewpoint

Groom’s detailed treatment makes the numerical example useful as a transaction map. SIMERPU would separate the premium, the benefit payment and any underlying medical expense rather than treating the illustration as a single savings number. Each component needs an explanation consistent with the program’s documents.

What this source contributes

The numerical example makes it possible to examine premiums, benefit payments and payroll treatment as separate parts of a transaction.

What remains unanswered

An employer needs to substitute its own facts carefully. Changing the dollar amounts alone does not explain a different tax result.

Mardy Gould’s take

Numbers can make this debate clearer. I would place the proposed paycheck next to the memo’s example and mark each meaningful difference. Then I would ask the provider to explain those differences in plain English. The employer should understand the reasoning behind the illustration, not just the final savings figure.

Questions I would bring to the conversation

1. What replaces the example’s premium and cash payment?

2. Which differences concern legal entitlement rather than amount?

3. Where is any underlying expense documented?

Mardy Gould · Co-Founder, SIMERPU →

What would change our assessment?

A transaction map identifying substantive differences and their legal rationale would improve the comparison; revised arithmetic alone would not.

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: Not individually identified

Publisher: Groom Law Group, Chartered

Original Publication Date: 2023-06-26

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About this source

Original Updated Date: 2023-06-26 (page metadata)

Source Type: Law firm analysis

Model Discussed: wellness indemnity payments

Position: Critical

Period: Recent — 2023–2026

Retrieved: October 31, 2026

Research and date notes

Date from article metadata; June 8 in body describes IRS release, not article publication.

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.