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

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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.