VEBA's distribution of funds to participating employers to pay future insurance premiums does not constitute reversion
Article Abstract:
This article describes the IRS's position in Private Letter Ruling 199916054 concerning the treatment of a voluntary employees' beneficiary association's (VEBA's) distribution to employers which were to use the funds in the future to purchase insurance premiums for the terminating VEBA participants. The IRC section 4976 excise tax would not be applicable and the section 501(c)(9) tax exemption would still apply. The application of the ruling may be limited due to ERISA requirements in other fact situations.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1999
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Master trust comprised of defined benefit plans and VEBA not tax-exempt under S501
Article Abstract:
The IRS has issued GCM 39873 stating that a master trust composed of defined benefit plans and a voluntary employees' beneficiary association (VEBA) trust is taxable. While the VEBA remains tax exempt on its own, the master trust does not qualify for exemption under section 501(a). The pooling of different benefit plans to maximize investment profits has been hurt by this GCM and corrective legislation could be needed.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1992
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IRS approves transfer of retired life type reserves to VEBA
Article Abstract:
The transfer of retired lives reserve accounts to a voluntary employees' beneficiary association is nontaxable, according to IRS Private Letter Ruling 9206030. The IRS ruled that the 100% prohibited transaction excise tax was not necessary because of an insurance policy provision that forbade any reversion of the amounts to the employer as long as any of the employees or retirees were still alive.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1992
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