SIMERPU RESEARCH · SOURCE RECAP
FICA Reduction Redux – IRS Issues Guidance on Wellness Indemnity Payments
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Credited law-firm bulletin critiques FICA-reduction programs and explains CCA 202323006’s treatment of wellness indemnity payments and employer withholding exposure.
SIMERPU’s viewpoint
The credited law-firm bulletin provides another explanation of the recurring FICA-reduction concern. SIMERPU would compare its reasoning with the underlying memorandum and the proposed arrangement. Multiple hosts of the same bulletin should be recognized as distribution of one analysis, rather than independent corroboration.
What this source contributes
The bulletin explains the recurring FICA-reduction concern and preserves a credited legal origin.
What remains unanswered
Multiple hosts distribute the same analysis; they do not supply separate supporting opinions or employer-specific facts.
Mardy Gould’s take
I would count this as one analysis and focus on the quality of its reasoning. Follow the cited memo, identify the transaction it describes and ask the provider to respond to that point. A stack of reposts should not make a single argument look more independently supported than it is.
Questions I would bring to the conversation
1. What is the credited original analysis?
2. Which memo facts support its conclusion?
3. How does the employer’s proposed payment compare?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
A substantiated factual distinction or additional independent analysis could improve the comparison; more syndicated copies would not.
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: Barrow Weatherhead Lent LLP
Publisher: Alera Group (host); Barrow Weatherhead Lent LLP (credited origin)
Original Publication Date: 2023-06-29
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
Read the underlying memorandum directly.
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 the earlier fixed-indemnity funding analysis.
Read the SIMERPU recap →
Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
Federal Register
Source position: Neutral / explanatory
Compare subsequent rulemaking context with the bulletin’s discussion.
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: Benefits consultant / administrator
Model Discussed: Wellness indemnity payments and their treatment under employment taxes
Position: Critical
Period: Recent — 2023–2026
Retrieved: October 31, 2026
Research and date notes
Same credited article also hosted by TIG Advisors on July 11, 2023; counted once. Alternate version/host: https://tigadvisors.com/guidance-on-wellness-indemnity-payments/
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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