Administrative Policy
24 July 2015 Folio S2-F1-C1
1.5 …There is no minimum number of employees that must be covered under a private health services plan.
25 June 2014 T.I. 2014-0521301E5 - PHSP - employee-shareholder
A cost-plus health plan ("Plan") administered by a third party (e.g., insurance company) is offered by a corporation to its sole shareholder who is also the sole employee. CRA stated:
[A] cost-plus plan under which the administrator agrees to reimburse the sole employee-shareholder, his or her spouse, and members of his or her household for actual medical and hospital expenses and receives, as consideration, an amount equal to the amount reimbursed plus an administrative fee, does not qualify as a PHSP since it does not contain the necessary elements of insurance.
26 May 1995 T.I. 950171 (C.T.O. "Self-Funded Private Health Services Plans")
A self-funded dental care plan can qualify as a private health services plan.
15 June 1993 T.I. (Tax Window, No. 32, p. 12, ¶2606)
A plan providing coverage for a partner of the same sex does not qualify as a private health services plan. Where it is not feasible to have a separate plan which is not a private health services plan, RC is prepared to treat a plan as being two separate plans provided the administrator accounts for contribution separately.
13 June 1991 T.I. (Tax Window, No. 4, p. 28, ¶1301)
An employer funded arrangement to cover employee medical expenses will not be a private health insurance plan if it permits excess contributions and medical expenses to be carried forward from year to year.