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 Readers should preserve the memo’s specific context and its status as nonprecedential advice.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
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
Compare the later wellness-policy example funded through salary reduction.
Read the SIMERPU recap →
CCA 201719025 — Tax Treatment of Benefits Paid by Self-Funded Health Plans
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Explore a different set of issues involving self-funded arrangements.
Read the SIMERPU recap →
Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
Federal Register
Source position: Neutral / explanatory
Place the historical advice alongside later rulemaking discussion.
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: 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.
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