- 4 - were irrevocable and could not revert to petitioner under the terms of the Trust Agreement. The VEBA Trust uses the cash method of accounting and has a fiscal year ending June 30. The VEBA Trust qualifies as a welfare benefit fund under section 419(e). The Parker-Hannifin Group Insurance Plan and the Long-Term Disability Plan for Salaried Employees of Parker-Hannifin Corporation were funded by the VEBA Trust. Pursuant to an administrative services agreement dated February 24, 1981, Provident Life and Accident Insurance Company (Provident) agreed to provide administrative services for certain of petitioner’s employee benefits. Provident continued to provide such services during the year in issue. On June 30, 1987, petitioner contributed $42 million (the 1987 contribution) to the VEBA Trust. Effective July 1, 1987, the maximum Federal corporate income tax rate decreased from 46 to 34 percent. Petitioner’s 1987 contribution to the VEBA trust included the following amounts: Incurred but unpaid medical, dental, & short-term disability benefits 1$9,022,227 Administration fees 2479,089 Long-term disability benefits 2,500,000 Union medical benefits 3,210,991 Postretirement benefits Retirees 10,779,650 Active employees 16,133,508 Total 3$42,125,465 1Respondent has allowed a deduction for this amount. 2Respondent has allowed a deduction for this amount. 3Petitioner’s chief financial officer suggested rounding the 1987 contribution to $42 million.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011