SIMERPU RESEARCH · SOURCE RECAP
IRS Opines on the Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policies
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Explains CCA 202323006’s rejection of the described tax treatment and connects it to earlier double-dipping arrangements.
SIMERPU’s viewpoint
McDermott’s explanation connects the 2023 memorandum with an earlier line of double-dipping concerns. SIMERPU would use that continuity to identify recurring payment issues while evaluating any material differences in a new structure. The history is useful when it produces a precise comparison of facts.
What this source contributes
The article places the 2023 memorandum within an identifiable history of premium-return concerns.
What remains unanswered
A different structure requires a precise factual comparison rather than an assumption that historical concerns either apply universally or are irrelevant.
Mardy Gould’s take
I would ask the provider to identify the recurring issue in this history and show how its design addresses it. That gives the employer something concrete to assess. The explanation should connect the claimed difference to the payment process and the employee’s records, while making the added benefits understandable as well.
Questions I would bring to the conversation
1. Which historical concern carries into the 2023 example?
2. What facts differ in the current proposal?
3. Where is the significance of that difference explained?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
A documented difference in the actual transaction could change the comparison with the historical pattern.
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: Jacob M. Mattinson, Sarah G. Raaii
Publisher: McDermott Will & Emery (article as published)
Original Publication Date: 2023-06-27
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
CCA 202323006 — Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policy
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Check the primary memo behind the article.
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
Review earlier advice on benefit funding and payments.
Read the SIMERPU recap →
Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
Federal Register
Source position: Neutral / explanatory
Compare subsequent rulemaking discussion with the historical analysis.
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: 2026-05-13 (page metadata)
Source Type: Law firm analysis
Model Discussed: Employer-funded, insured, fixed-indemnity wellness policies
Position: Critical
Period: Recent — 2023–2026
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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