pjr@frdayton.com Posted April 13 Report Share Posted April 13 Will the IRS issue a private letter ruling with respect to the termination and final distribution of VEBA assets or is this a no ruling area. Thanks. Link to comment Share on other sites More sharing options...
Luke Bailey Posted May 12 Report Share Posted May 12 I think they generally will. I have received letter rulings in connection with VEBA terminations that involved the distribution of disability annuities, for example, and the tax issues for the employees were novel so we needed the comfort of a ruling. There are a couple of "no-ruling" areas covered in Rev. Proc. 2022-1, however. These no-ruling areas do not directly involve termination, but rather amendments to VEBAs that implicate the tax benefit rule or the reversion excise tax in the case of a transfer of assets from one VEBA to another. Luke Bailey Senior Counsel Clark Hill PLC 214-651-4572 (O) | LBailey@clarkhill.com 2600 Dallas Parkway Suite 600 Frisco, TX 75034 Link to comment Share on other sites More sharing options...
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