Individual is the sole employee/owner of a C Corp. He wants to establish a medical reimbursement account to "pick up" anything that his health insurance does not cover. He also wants this Plan to be "retroactive" for four months (back to when he incorporated). This will be funded entirely by "employer" contributions (no 125 Plan).

1) I assume the Plan cannot be retroactive because Prop. Reg. 1.125-1 Q&A 17 is applicable to all 105 Plans even those not funded through a 125 Plan. Do you agree?

2) If there is only 1 employee do I avoid any 105 discrimination issues?

3) Any other problems that you see here

Generally in a 1 person corp I would not worry about discrimination; but review 105(h)

In a 1 person C-Corp. what documentation is needed to provide medical reimbursement to the sole employee (who is also the 100% owner)?