[The Section 132(e)
de minimis exclusion, which applies when it would otherwise be unreasonable or administratively impractical to account for the benefit due to the minimal value, never applies to any cash fringe benefit, however.] Reimbursements or payments of gym membership fees must also be included. The memorandum stipulates that any reward, incentive, or other benefit provided by a medical program that isn’t medical care, as defined under IRC Sec. 213(d) , is included in an employee’s income unless it’s excludible as an employee fringe benefit under IRC Sec. 132 . CCA 201622031.
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