- 16 - permits a deduction for the taxable year in which the contribution is paid, subject to the limitation contained in section 419(b). Section 419(b) limits the deduction for any taxable year to the welfare benefit fund’s “qualified cost”.15 The fund’s qualified cost is equal to the sum of the fund’s “qualified direct cost” for the year, and, subject to the limitation of section 419A(b), any addition to a “qualified asset account” for the year.16 Sec. 419(c)(1). Section 419A(a) defines a qualified asset account as any account consisting of assets set aside to provide for the payment of (1) disability benefits, (2) medical benefits, (3) SUB (supplemental compensation benefit) or severance pay benefits, or (4) life insurance benefits. Additions to a qualified asset account are included in the fund’s qualified cost only to the extent they do not exceed the fund’s “account limit” for the taxable year. Sec. 419A(b). For purposes of the present case, the account limit includes: (1) The amount reasonably and actuarially necessary to fund claims that are incurred but unpaid as of the close of the taxable year and related administrative costs and (2) the amount of an 15 A contribution to a welfare benefit fund in excess of that year’s qualified cost is treated as a contribution by the employer to the fund during the succeeding taxable year. Sec. 419(d). 16 The fund’s qualified cost for the taxable year is reduced by the fund’s after-tax income for that year. Sec. 419(c)(2).Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011