54 pages; working paper. Excerpt: Although there are socially useful reasons for having VEBAs and protecting the ability of small businesses using VEBAs to provide the much needed welfare benefits ... there is the potential for misuse and schemes by those seeking only to evade taxes.... Although VEBAs fell into disfavor as a tax-planning device initially as a result of [DEFRA in 1984], Congress left an exception in the law for so-called multiple-employer VEBAs.