- 12 - 419A(c) provides: SEC. 419A. QUALIFIED ASSET ACCOUNT; LIMITATION ON ADDITIONS TO ACCOUNT. (c) Account Limit.–-For purposes of this section–- (1) In general.–-Except as otherwise provided in this subsection, the account limit for any qualified asset account for any taxable year is the amount rea- sonably and actuarially necessary to fund–- (A) claims incurred but unpaid (as of the close of such taxable year) for benefits referred to in subsection (a), and (B) administrative costs with respect to such claims. (2) Additional reserve for post-retirement medical and life insurance benefits.–-The account limit for any taxable year may include a reserve funded over the working lives of the covered employees and actuarially determined on a level basis (using assumptions that are reasonable in the aggregate) as necessary for–- (A) post-retirement medical benefits to be provided to covered employees (determined on the basis of current medical costs) * * * We turn now to the initial dispute between the parties over whether, in determining for each year at issue the Trust’s UBTI under section 512(a)(3)(A), the amount of investment income at issue that the Trust set aside (i.e., $1,580,455 for 1991 and $1,155,793 for 199214) to provide for the payment of reasonable costs of administration directly connected with providing for the payment of health care benefits is subject to the limitation prescribed by section 512(a)(3)(E)(i). It is the position of the 14See supra notes 4, 8, and 10.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011