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Posted

Our client offers an onsite medical clinic for its employees providing non-significant services (e.g., band-aides, temperature check, etc.). Should the value of the service be imputed as income for the employees making use of the clinic? If not, under what tax code section are these services excluded -- Section 106 (employer coverage)? Section 132 (fringe benefit)? Has the IRS put out any guidance on this topic? Thanks in advance.

Posted

If the benefit is really de minimu, it is a fringe plan and there should be no imputed income. If they can get medical exams, treatments for illness or injuries (more significant than those which require a band-aid), then it seems like the value of the benefit should be imputed income. I have no idea how that value would be determined.

Posted

See Section 132(e)(i). It allows for non-taxation of de minimu services, which is what you have here. By the way, if the employee/patient has an account based plan (hsa), there must be a charge to the employee/patient.

Good luck.

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