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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.
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