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You must offer employees benefits on a nondiscriminatory basis. Nondiscriminatory means you can’t offer men health insurance and not woman as this is gender based discrimination. You can offer certain categories of employees benefits that other employees are not eligible. The IRS may disallow a tax deduction if the plan is discriminatory as well. The more basic question is fairness. Unless there is a major reason why you would always be better to offer all your employees a benefit so that you don’t have us against them mentality but were all in it together for team building.