<< Under the terms of An Accountable Plan, that could be nonreportable and nontaxable reimbursement, >>

"...that could be..." 

Could be? If what? I'm less interested in what it could be and more interested in what it IS.

"...over and above the provision..."

What provision?

You mean the % they've been using for 10 years? Is that considered "a provision"?

Honestly, it still sounds to me like you're saying they won't be paying taxes on the benefit they're receiving. You denied that you're saying that, but you say that it's not reportable and nontaxable, and if that's the case, then they're avoiding taxation, which still sounds like fraud to me. Please explain how it's not fraud if they don't report it or pay taxes on it.