Commentary: Earlier this year, the Internal Revenue Service clarified that it would not consider the value of credit monitoring and other identity protection services provided by employers to employees in connection with a data breach to be taxable income to the employees. IRS Announcement 2015-22. In response to comments, the IRS expanded this tax treatment to apply when employers provide such services before a breach happens. IRS Announcement 2016-02.
In the more recent Announcement, the IRS concludes:
