SIMERPU RESEARCH · SOURCE RECAP

CCA 201703013 — Tax Treatment of Benefits Paid by Fixed-Indemnity Health Plans

SIMERPU recap and commentary: Mardy Gould

Opened — main text retrieved

Quick recap

Examines fixed-indemnity benefits under different funding situations, including employer funding and employee pre-tax salary reductions, distinguishing coverage exclusions from benefit-payment treatment.

SIMERPU’s viewpoint

This memorandum shows why the source of funding matters when discussing fixed-indemnity benefits. SIMERPU would identify the treatment of contributions and benefit payments separately, then compare the relevant facts. Readers should preserve the memo’s specific context and its status as nonprecedential advice.

What this source contributes

The funding scenarios show why coverage and later benefit payments should be analyzed separately.

What remains unanswered

The memo does not identify the funding mix or policy terms of a current offer. Those details must be established before borrowing an example’s conclusion.

Mardy Gould’s take

I would want a simple funding table before discussing the result: employer contributions, employee pre-tax contributions and employee after-tax contributions. Then show the benefit paid under each relevant policy. That prevents a conversation about one funding arrangement from being used to explain a different one without anyone noticing.

Questions I would bring to the conversation

1. Who funds each coverage component?

2. Which contributions are included in employee income?

3. Which policy pays the benefit being analyzed?

Mardy Gould · Co-Founder, SIMERPU →

What would change our assessment?

A verified difference in contribution treatment or benefit terms could change which scenario is relevant and warrants a fresh comparison.

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: Stephen Tackney

Publisher: IRS Office of Chief Counsel

Original Publication Date: 2017-01-20

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About this source

Original Updated Date: Not stated

Source Type: Government — nonprecedential tax memorandum

Model Discussed: Fixed-Indemnity Health Plans

Position: Neutral / explanatory

Period: Historical — through 2022

Retrieved: October 31, 2026

Research and date notes

Release date; memorandum dated 2016-12-12. Nonprecedential advice addressing particular arrangements.

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.