SIMERPU RESEARCH · SOURCE RECAP

Revenue Ruling 2002-3 — Reimbursement of pre-tax health insurance premiums

SIMERPU recap and commentary: Mardy Gould

Opened — main text retrieved

Quick recap

Holds that reimbursing employees for health premiums already funded through excluded salary reductions does not qualify for the asserted income and employment-tax exclusions.

SIMERPU’s viewpoint

Revenue Ruling 2002-3 supplies a primary source for understanding the pre-tax premium-reimbursement issue. SIMERPU would use its facts to examine whether a proposed payment returns a premium already treated favorably or reimburses a different expense. The distinction should be demonstrated through the transaction records.

What this source contributes

The ruling supplies the original facts and reasoning for the pre-tax premium-reimbursement issue.

What remains unanswered

Applying it to a new proposal requires identifying whether the payment returns the same premium or addresses a different expense.

Mardy Gould’s take

I would trace the original premium and the later payment before accepting anyone’s description of double dipping. What was already excluded, what is being reimbursed and how do the records connect? That makes the discussion precise and gives a provider a fair opportunity to demonstrate a materially different transaction.

Questions I would bring to the conversation

1. Was the original premium paid through excluded salary reduction?

2. What exactly does the later payment reimburse?

3. What records distinguish any separately claimed expense?

Mardy Gould · Co-Founder, SIMERPU →

What would change our assessment?

Evidence that a different expense and entitlement are involved could change the factual comparison with the ruling.

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: IRS; principal author Janet A. Laufer

Publisher: IRS

Original Publication Date: 2002-01-22

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About this source

Original Updated Date: Not stated

Source Type: Government — revenue ruling

Model Discussed: Employer reimbursements for health insurance premiums

Position: Neutral / explanatory

Period: Historical — through 2022

Retrieved: October 31, 2026

Research and date notes

Published in IRB 2002-3, p. 316. Standalone three-page ruling retrieved; bulletin copy deduplicated. Alternate version/host: https://www.irs.gov/pub/irs-irbs/irb02-03.pdf

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.