CRA considers that:
In a situation where a corporation provides a self-insured HCSA for its only employee who is also its sole shareholder … , it is likely that the sole employee-shareholder would be reimbursed for the full amount allocated to him or her annually.
On this basis, CRA would view the arrangement as not being a plan of insurance and, thus, not a private health services plan, so that there would be a taxable benefit to the employee-shareholder, even where the benefits were comparable to those available to non-shareholder employees performing similar services for similarly-sized businesses.