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appropriate to carry out the purposes of this
subpart. Such regulations may provide that
the plan administrator of any welfare benefit
fund which is part of a plan to which more
than 1 employer contributes shall submit such
information to the employers contributing to
the fund as may be necessary to enable the
employers to comply with the provisions of
this section.
A fund's QAA consists of any assets set aside to provide for
the payment of (1) disability benefits, (2) medical benefits,
(3) supplemental unemployment compensation benefits (SUB) or
severance pay benefits, or (4) life insurance benefits. Sec.
419A(a). No addition to a QAA which causes the account balance
to exceed the account limit may be considered as a portion of the
qualified cost under section 419(c)(1)(B). Sec. 419A(b). The
account limit for any taxable year consists of two separate
elements, each of which is in issue in the instant case.
The first element of the account limit is the amount
reasonably and actuarially necessary to fund CIBU's as of the
close of the taxable year, as well as administrative costs
related to such claims. Sec. 419A(c)(1). In the event that the
CIBU's are not actuarially determined, the deduction can be no
greater than certain safe harbor percentages. Sec. 419A(c)(5).
The second element of the account limit is a reserve funded over
the working lives of covered employees and actuarially determined
on a level basis (using assumptions that are reasonable in the
aggregate) as necessary for PRMB's to be provided to covered
employees (determined on the basis of current medical costs) or
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