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 care costs the employee incurs while in the U.S. CRA stated:
[A] plan is a PHSP, amongst other conditions, if ‘all or substantially all’ of the premiums paid under the plan relate to medical expenses that are eligible for the medical expense tax credit (METC). “All or substantially all” generally means 90% or more.
… Folio S1-F1-C1 … states that, notwithstanding several exceptions, “eligible medical expenses are not restricted to those paid in Canada or for medical services provided in Canada”.
Whether ‘all or substantially all’ of the premiums paid under the … plan relate to medical expenses that are eligible for the …METC … is a question of fact and can only be determined by the insurer of the plan.