Administrative Policy
3 May 2022 CALU Roundtable Q. 10, 2022-0928901C6 - 2022 CALU – Q10 – Private Health Services Plan
Can a health spending account (HSA) (under which an employer agrees to reimburse its employees’ hospital and medical expenses incurred during...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | single shareholder/employee HSA does not qualify | 137 |
26 January 2021 External T.I. 2020-0857841E5 - HCSA
In 2020-0846751E5, CRA noted that the terms of a health care spending account (“HCSA”) would, in most cases, comply with IT-529, which...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | extension during COVID of the period for carrying forward unused HCSA credits | 275 |
2 June 2020 External T.I. 2020-0847081E5 F - Compte de frais médicaux – période de report
Due to the COVID-19 pandemic, plan members of a health care spending account (“HCSA”) may not be able to incur eligible medical expenses or...
25 May 2020 External T.I. 2020-0846751E5 - HCSA unused credits
Due to the curtailment of services during the COVID-19 pandemic, plan members of a health care spending account (“HCSA”) may not be able to...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | unused HCSA credits can be carried forward for up to an additional 6 months during COVID-19 | 183 |
24 January 2019 External T.I. 2016-0651291E5 - Revised PHSP position - Self-insured plan
For insured and self-insured private health services plans (PHSPs), what are the tax consequences if not all or substantially all of the actual...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | employee allocated ceiling amounts do not affect application of 90% METC-eligible expense test where a self-inusred plan | 211 |
22 January 2019 External T.I. 2016-0645581E5 - Health and welfare trusts (HWTs)
CRA indicated that a health and welfare trust (“HWT”) which is jointly established by a union and multiple employers, can provide benefit...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | HWT can administer a plan that is funded only with union or employee contributes where it also has employer-funded plans | 478 |
12 December 2018 External T.I. 2017-0718661E5 - Private health services plan
The purpose of a Blue Cross and Blue Shield insurance plan (XXXXXXXXXX Blue Cross plan is to reimburse an employee for certain medical and health...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | coverage for U.S. expenses of METC type generally eligible | 115 |
14 September 2017 Roundtable, 2017-0703871C6 - CPA Alberta 2017 Q9: PHSP for owner-managers
Provided that an employee (who is also a shareholder) is active in the business of a corporation whose only employees are also shareholders, and...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | sole employee-shareholder unlikely to qualify for PHSP | 103 |
May 2017 CPA Alberta Roundtable, ITA Q.9
A small business only having employee(s) who are also shareholder(s), establishes a notional health care spending account(s) (a type of “private...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | general presumption that employee-shareholder receives health care spending account benefits as shareholder | 128 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | HCSA for sole shareholder-employee unlikely to operate as insurance plan | 200 |
8 December 2014 External T.I. 2014-0543891E5 F - Régime privé d'assurance-maladie
In the course of a general discussion of a flex plan, CRA stated:
Where a plan or arrangement covers expenses other than medical expenses, the...
S2-F1-C1 - Health and Welfare Trusts
1.5 …There is no minimum number of employees that must be covered under a private health services plan.
25 June 2014 External 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...
15 October 2013 External T.I. 2013-0498001E5 F - Transfert de sommes inutilisées entre régimes
Is it possible for the employer (a university) to reallocate the unused credits from the individual healthcare spending account for professional...
1 December 2010 External T.I. 2010-0385491E5 F - Postes isolés dans la fonction publique
Federal employees working at isolated posts are reimbursed for travel expenses (travel and accommodation) incurred in relation to the medical...
13 May 2010 External T.I. 2009-0328741E5 F - Régime "à prix coûtant majoré"
Under a "cost-plus" plan offered to company executives, they are reimbursed for health expenses not otherwise reimbursed by their group insurance,...
18 July 2008 External T.I. 2008-0271211E5 F - Fiducie de santé et de bien-être
Members of a provincial professional association (the "Employers") are eligible to join a multi-employer health insurance plan (the “Plan”)...
6 May 2008 External T.I. 2007-0254661E5 F - Partie B Medicare
Regarding whether premiums paid to the U.S. Medicare (Part B) plan qualified for the medical expense credit, CRA stated:
Medicare appears to...
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| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | U.S. Medicare Part B premiums are not non-business income tax | 124 |
17 March 2008 External T.I. 2006-0216751E5 F - Régime individuel - RAMQ - Retraité
Are the premiums paid by the employer for individual insurance policies for retirees under the Quebec General Drug Insurance Plan (“RGAMQ”) a...
26 May 1995 External T.I. 9501715 - SELF-FUNDED PRIVATE HEALTH SERVICES PLANS
A self-funded dental care plan can qualify as a private health services plan.
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 15 |
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...
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...