- quote -

Check out Rev Ruling 2004-45. This may help. An HRA and
FSA can be qualified HDHP provided they meet the HDHP
criteria.

Also, Notice 2004-2 and Notice 2004-23 might be helpful.

From what I understand, everything (the HRA and the
insurance) must both qualify as HDHP's as defined in IRC
Section 223.

<< ================================================== ===== > << The foregoing was not intended or written to be used, > << nor can it used, for the purpose of avoiding penalties > << that may be imposed upon the taxpayer. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >

Proposal for health plan: (small business, C Corp, all
employees are owners)

Set up HSAs for first dollar medical expenses.

Section 105 HRA will kick in at the allowable upper limit of
the deductible.

Overlay a very high deductible catastrophic health insurance
policy.

So, for example, single employee's health care costs:

$0.01 to $2,700 (or whatever the limit is) will be paid by
the Health Savings Account.

$2,700.01 to $10,000.00 will be paid by the employer's
Section 105 HRA

$10,000.00 and above will be covered by the catastrophic
policy.

So, in essence, the HRA is the qualified HDHP. Will this
pass muster with the IRS?

Thanks!

<< ================================================== ===== > << The foregoing was not intended or written to be used, > << nor can it used, for the purpose of avoiding penalties > << that may be imposed upon the taxpayer. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >