What does the IRS say?
The BASEĀ® HRA is based on several sections of the Internal Revenue Code, including Sections 105, 106, 162, 213, and Revenue Ruling 71-588. In 1994, the IRS issued a National Office Technical Advice Memorandum regarding this plan. In 1999, the IRS Industry Specialization Program offered a coordinated issue paper regarding Section 105. The latest information released by the IRS was Notice 2002-45, and Revenue Ruling 2003-102.