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such excess shall be treated as an amount paid by the
employer to such fund during the succeeding taxable
year.
Section 419 provides that an employer's deduction for
contributions to a WBF, including a VEBA, during a taxable year
may not exceed the fund's "qualified cost" for the taxable year.
The qualified cost is the sum of qualified direct cost (QDC)
and any additions to a qualified asset account (QAA), subject to
the limitations of section 419A(b), less after-tax income for the
year. Sec. 419(c). The QDC is the aggregate amount, including
administrative expenses, which would have been allowable as a
deduction to the employer with respect to the benefits provided
during the tax year if the employer had provided those benefits
directly rather than through the funds and used the cash receipts
and disbursements method of accounting. Sec. 419(c)(3)(A). Such
benefits are deemed provided at the time they would have been
includable in the gross income of the employees if provided
directly by the employer (disregarding any provision which would
otherwise exclude such benefits from gross income). Sec.
419(c)(3)(B). If a contribution exceeds the year's qualified
cost, the excess is treated as a contribution by the employer to
the fund during the succeeding taxable year. Sec. 419(d).
Pursuant to the foregoing framework, a deduction is available
only for contributions made during the taxable year for benefits
actually provided during the taxable year (with the exception of
additions made to QAA's for CIBU's and PRMB's). Accordingly,
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