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
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 the ruling underlying earlier premium-reimbursement concerns.
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
Follow the later advice on wellness rewards and premium refunds.
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
Compare the historical pattern with the more recent insured wellness example.
Read the SIMERPU recap →
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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.
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