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Employer Student Loan Repayment Benefits – Question

Understanding Employer Student Loan Repayment Benefits: What You Need to Know

Navigating the landscape of employee benefit programs can often feel complex, especially when it comes to recent legislative changes aimed at assisting employees with student loan debt. One such benefit that has gained attention is the employer-sponsored student loan repayment program, which allows companies to contribute up to $5,250 annually on a pre-tax basis, thanks to provisions originally established under the CARES Act and made permanent by the Better Business Act (BBB).

The Opportunity for Employees

These programs present a valuable opportunity for employees to reduce their taxable income while alleviating student loan burdens. For instance, some companies consider innovative approaches, such as adjusting healthcare premium contributions to facilitate additional voluntary employee payments that can be matched or supplemented by the employer’s student loan contributions.

In the scenario addressed, an employee proposed a strategy where employees voluntarily increased their healthcare premium contributions up to the $5,250 limit. The employer would then match that amount with another $5,250 in student loan repayments, both structured as pre-tax benefits. The goal: to help employees lower their Adjusted Gross Income (AGI), potentially reducing the overall interest or monthly payments on their student loans.

Clarifying Employer Concerns and IRS Regulations

However, complications arise when interpreting IRS rules and regulations surrounding these benefits. The company’s HR department pointed out that, based on an IRS guidance on taxable fringe benefits, such arrangements might not qualify under existing law. They highlighted a specific rule related to educational assistance programs, which states:

“The program doesn’t allow employees to choose to receive cash or other benefits that must be included in gross income instead of educational assistance.”

This clause raises the question: does this restriction prevent the employer from offering a student loan repayment benefit that is linked to increased healthcare contributions?

My Perspective

From a practical standpoint, healthcare premium costs are generally excluded from gross income, and employers are permitted to structure benefits to minimize tax implications. The IRS has clarified that employer contributions toward student loans can be considered a form of educational assistance, potentially making them tax-exempt if properly structured.

The critical element here appears to be the intent and structure of the program. If the benefit is offered as a distinct, written educational assistance plan that explicitly provides for student loan repayment—separately from cash or other taxable benefits—then it may qualify under IRS rules. Additionally, linking the payment to voluntary employee contributions, such as healthcare premiums, might complicate compliance unless carefully structured to meet IRS requirements

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