SIMERPU RESEARCH · LIMITED-ACCESS NOTE
IRS Sees Rise in Wellness Plan Double-Dipping Tax Strategies
SIMERPU recap and commentary: Mardy Gould
Partial — public excerpt; subscription prompt
Recap of the available material
The accessible excerpt reports an IRS official’s concern about renewed double-dipping wellness strategies marketed as employment-tax savings.
SIMERPU viewpoint on the available material
The available excerpt reports concern about renewed double-dipping strategies. SIMERPU treats that as a reason to examine the specific transactions under discussion, while recognizing that the full article may add qualifications and responses. The excerpt supports a limited recap, not a complete assessment of the reporting.
What the available material contributes
The public excerpt documents reported IRS concern about renewed strategies marketed as employment-tax savings.
What remains unanswered
The full reporting may include context, responses or qualifications unavailable in the excerpt. Our assessment cannot extend to those unseen passages.
Mardy Gould’s take
The excerpt gives me a reason to investigate the specific transactions being discussed. I would want the complete article before repeating its broader conclusions or characterizing anyone’s response. For an employer, the useful next step is to compare the reported concern with the actual payment process under consideration.
Questions I would bring to the conversation
1. Which transactions prompted the reported concern?
2. What qualifications or responses appear in the full article?
3. How do those facts compare with the employer’s proposal?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
Access to the complete reporting and its context could expand or qualify this limited assessment.
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 stated
Publisher: Bloomberg Industry Group
Original Publication Date: 2026-05-28
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
Revenue Ruling 2002-3 — Reimbursement of pre-tax health insurance premiums
IRS
Source position: Neutral / explanatory
Read an original ruling on pre-tax premium reimbursement.
Read the SIMERPU recap →
CCA 201622031 — Tax Treatment of Wellness Program Benefits and Employer Reimbursement of Premiums Provided Pre-tax Under a Section 125 Cafeteria Plan
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Compare the later advice on related reward and reimbursement arrangements.
Read the SIMERPU recap →
CCA 202323006 — Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policy
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Examine the more recent fixed-indemnity example as a separate primary source.
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: 2026-05-28 (page metadata)
Source Type: Trade / tax news publication
Model Discussed: Employer wellness plans and double-dipping tax avoidance strategies
Position: Neutral / explanatory
Period: Recent — 2023–2026
Retrieved: October 31, 2026
Research and date notes
Date from article metadata. Summary limited to retrieved excerpt.
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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