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A plan to be funded by a VEBA was established in the last part of a calendar year, but no money went into the trust until the beginning of the following calendar year. Is a Form 990 due for the calendar year in which the plan was established, or is the first 990 due for the calendar year in which the trust was established (i.e., the date assets were placed into trust)? In other words, can the trust be viewed as nonexistent (i.e., no 990 required) until the date that dollar one was placed into trust?

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