SIMERPU RESEARCH · SOURCE RECAP

Double Dip Tax

SIMERPU recap and commentary: Mardy Gould

Opened — main text retrieved

Quick recap

Historical warning about wellness banks and similar arrangements promising free benefits and increased take-home pay. Discusses circular premium reimbursements and earlier IRS guidance.

SIMERPU’s viewpoint

The historical discussion of wellness banks shows why earlier program designs remain relevant to present-day questions. SIMERPU would compare transaction patterns across time while checking whether a current proposal has materially different facts. The useful lesson is to recognize the mechanism behind a familiar financial promise.

What this source contributes

The historical discussion makes recurring premium-return patterns easier to recognize across changing product names.

What remains unanswered

A present proposal still needs a factual comparison; a shared savings promise does not establish identical transactions.

Mardy Gould’s take

I would use the history to ask better questions about today’s offer. Show the old transaction beside the new one and identify what changed. If the provider has developed a different approach, the explanation should make that difference visible in the documents and the actual flow of money.

Questions I would bring to the conversation

1. What historical transaction is described?

2. Where does the current proposal differ?

3. Which records demonstrate the difference?

Mardy Gould · Co-Founder, SIMERPU →

What would change our assessment?

Documented changes in funding, entitlement or reimbursed expenses could change the comparison with the historical design.

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: HUB’s EB Compliance Team

Publisher: HUB International

Original Publication Date: 2020-06-09

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About this source

Original Updated Date: Not stated

Source Type: Benefits consultant / administrator

Model Discussed: Double-Dip tax schemes

Position: Critical

Period: Historical — through 2022

Retrieved: October 31, 2026

Research and date notes

No additional retrieval note.

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.