"[I]nasmuch as [FASB 106] has required employers to account for retiree welfare benefits as either an expense on the employer's income statement or by amortization of the liability on a straight line basis since 1992, for which the aggregate impact on employers is in the billions of dollars, Tackett's significance will be felt in three ways: [1] Rust-belt company balance sheets could improve significantly. [2] Employers could terminate or modify union retiree plans, e.g., by charging premiums and increasing co-payments. [3] Future union negotiations of retiree welfare benefits are likely to be even more contentious." [M&G Polymers USA, LLC v. Tackett, No. 13-1010 (U.S. Jan. 26, 2015)]