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Small Business Covering Insurance Premiums for one NHCE, Best Option?


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I have a scenario I found rather odd.  I have a small business that wishes to cover insurance premiums for one NHCE, excluding all others and all HCEs.  I feel as though I could get away with an HRA not integrated with group insurance/QSEHRA, but I'm just not sure if excluding everyone else will qualify it as a "one employee" plan.  The sponsor doesn't want the employee to be taxed, hence looking into a 105 plan.

Thanks for any help in advance!  

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