SIMERPU RESEARCH · SOURCE RECAP
Wellness and the Tax Law
SIMERPU recap and commentary: Mardy Gould
Opened — full 75-page journal PDF retrieved
Quick recap
Examines tax subsidies for medical care and the boundary with general wellness. Evaluates competing reform approaches, including broader wellness coverage, narrower subsidies and a restructured subsidy; does not validate SIMERP payroll arrangements.
SIMERPU’s viewpoint
The scholarship broadens the conversation from program marketing to the purpose of medical-care tax subsidies. SIMERPU sees value in examining why the boundary between treatment and general wellness exists and how different policy choices might affect it. Reform arguments should remain distinguishable from the rules governing a present proposal.
What this source contributes
The scholarship examines competing policy choices rather than treating the existing medical-care boundary as self-explanatory.
What remains unanswered
Arguments for reform do not establish the treatment of a current payroll program or prove its implementation facts.
Mardy Gould’s take
I think this is valuable reading because it asks what the tax system is trying to encourage. Better access to useful services deserves discussion. I would keep that policy conversation separate from the immediate question an employer must answer: what supports the treatment of the specific arrangement being proposed today?
Questions I would bring to the conversation
1. Is the passage describing current rules or proposing reform?
2. Who benefits under the competing policy approaches?
3. What does the argument establish about a particular program, if anything?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
New policy or authoritative legal developments could alter the framework; a persuasive reform argument alone does not change an operating rule.
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: Leigh Z. Osofsky
Publisher: Georgia Law Review
Original Publication Date: 2025
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
Illness/Wellness, Ableism & Perfectibility in the Tax Code
UMKC Law Review
Source position: Critical
Compare another scholarly perspective on health norms and tax incentives.
Read the SIMERPU recap →
Frequently asked questions about medical expenses related to nutrition, wellness and general health
IRS
Source position: Neutral / explanatory
See practical IRS examples of the medical-care and wellness boundary.
Read the SIMERPU recap →
26 CFR §1.105-2 — Amounts expended for medical care
eCFR / Office of the Federal Register
Source position: Neutral / explanatory
Contrast policy proposals with the reimbursement regulation’s wording.
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: Journal-version date not verified
Source Type: Academic publication
Model Discussed: Tax law's medical care subsidy
Position: Neutral / explanatory
Period: Recent — 2023–2026
Retrieved: October 31, 2026
Research and date notes
Vol. 59, no. 2, article 3, pp. 443–516. Earlier SSRN posting 2024-09-09 and UNC copy are versions of the same scholarly work.
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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