What is a Section 105 plan?

Quick Answer
A Section 105 plan is an IRS-recognized medical reimbursement arrangement that lets a business reimburse medical expenses tax-free. For self-employed households, the classic setup runs reimbursements through a legitimately employed spouse.
Section 105 is the oldest trick in the tax-advantaged health playbook, and the most misunderstood. Done right, it converts family medical costs into legitimate business expense. Done sloppy, it converts an audit into a bad month.
How does the classic setup work?
The business legitimately employs the owner’s spouse — real work, real hours, payroll records. The business then offers the employee (the spouse) a Section 105 medical reimbursement benefit covering the employee’s family, which includes the owner. Family medical costs flow through the business as a deductible benefit expense.
What makes or breaks it?
Documentation. The employment must be real, compensation reasonable, and the plan documents in place before reimbursements start. Entity type matters too — the math changes across sole proprietorships, LLCs, and S-corps, and S-corp owners face the same family-attribution walls that complicate ICHRA participation.
ProtectHealth’s standing rule applies double here: insurance nerds, not tax professionals. A Section 105 conversation that skips the tax professional is a conversation happening in the wrong order. The broader landscape of structures sits in the parent guide, What Is An ICHRA?, and the tax-advantaged comparison.
Frequently Asked Questions
Who can use a Section 105 plan?
Businesses with W-2 employees can use Section 105 plans. Self-employed owners typically access the structure by legitimately employing a spouse, since owners themselves are generally not eligible employees for their own plan.
What can a Section 105 plan reimburse?
A Section 105 plan can reimburse qualifying medical expenses, including health insurance premiums, deductibles, dental, and vision costs, depending on plan design.
What makes a spouse's employment legitimate for Section 105?
Legitimate employment means real work performed, reasonable compensation, payroll records, and documented hours — not a paper arrangement. Weak documentation is the primary reason Section 105 setups fail under review.
Is a Section 105 plan the same as an ICHRA?
No. ICHRA is a specific type of HRA focused on reimbursing individual insurance premiums for employee classes. Section 105 is the broader reimbursement authority, and classic Section 105 strategies center on the employed-spouse setup.
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Book A ConversationProtectHealth brokers are insurance professionals, not tax professionals. Eligibility for any coverage or tax-advantaged structure depends on business structure, income, and household situation.