SIMERPU RESEARCH · SOURCE RECAP
IRS Warns Employers To Beware Of The "Double Dip"
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Insurer explanation contrasts questionable tax-saving wellness pitches with compliant benefit designs. Warns about premium-return payments and later tax liabilities.
SIMERPU’s viewpoint
American Fidelity’s explanation is useful background on premium-return concerns, with an explicit limitation that it was not updated after November 2023. SIMERPU would use it to understand the historical warning and then examine later developments separately. Preserving that date boundary helps readers assess what the article can support.
What this source contributes
The article provides an insurer’s explanation of premium-return concerns and clearly limits its update period.
What remains unanswered
Its express November 2023 cutoff means later developments require separate review.
Mardy Gould’s take
I appreciate a source that tells the reader where its coverage ends. I would use this explanation for the historical concern, then add the later materials before discussing a current proposal. That keeps an employer from mistaking an older article for a complete statement of everything that happened afterward.
Questions I would bring to the conversation
1. Which facts does the insurer’s warning address?
2. What relevant developments followed November 2023?
3. How does the current proposal compare with the described premium return?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
Later authority or materially different program facts could refine the article’s application; the publication’s own date limit should remain visible.
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: American Fidelity
Original Publication Date: 2023-11-14
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 foundational premium-reimbursement ruling.
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 related reward and premium-return advice.
Read the SIMERPU recap →
Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
Federal Register
Source position: Neutral / explanatory
Add the 2024 tax-related rulemaking discussion beyond the article’s cutoff.
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: Insurer-hosted analysis
Model Discussed: Tax avoidance strategy in wellness programs
Position: Critical
Period: Recent — 2023–2026
Retrieved: October 31, 2026
Research and date notes
Source explicitly says not updated for changes after November 2023.
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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