SIMERPU RESEARCH · SOURCE RECAP
Beware of tax promoters purporting to save employment taxes on health plans
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Examines marketed wellness and health plans, risk-shifting and unexpectedly large benefits relative to contributions. Discusses tax reporting and correction considerations.
SIMERPU’s viewpoint
The article’s discussion of risk-shifting and benefits relative to contributions invites a closer look at the program’s economics. SIMERPU would examine how obligations are funded and what uncertainty the arrangement actually covers. Those questions can help employers understand the product they are buying, as well as the tax claims made for it.
What this source contributes
The article asks how benefit promises relate to contributions and economic risk, extending review beyond tax-code citations.
What remains unanswered
The actual funding obligations and possible outcomes of a particular program still need to be demonstrated.
Mardy Gould’s take
I would ask what happens when reality differs from the illustration. Who owes the benefit, what funds it and what can change? Those questions help an employer understand the product itself. They also make it easier to evaluate whether the financial explanation is consistent with the coverage being described.
Questions I would bring to the conversation
1. Who is obligated to pay benefits?
2. What uncertainty does the arrangement cover?
3. How are payments beyond expected contributions funded?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
Verified funding and risk arrangements could change the factual comparison with the designs criticized.
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: Deborah Walker, CPA, and Richard Barnes, J.D., LL.M.
Publisher: The Tax Adviser
Original Publication Date: 2017-09-21
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
CCA 201719025 — Tax Treatment of Benefits Paid by Self-Funded Health Plans
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Read the primary memo examining predictable benefits and self-funded arrangements.
Read the SIMERPU recap →
CCA 201703013 — Tax Treatment of Benefits Paid by Fixed-Indemnity Health Plans
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Compare the insured funding scenarios.
Read the SIMERPU recap →
What do we need to know when approached by vendors offering payroll tax savings programs?
WTW
Source position: Critical
Use practical vendor questions to assign ownership of the financial explanation.
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: Professional accounting / benefits publication
Model Discussed: Health reimbursement arrangements marketed as tax-saving plans but not qualifying as insurance due to lack of risk shifting.
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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