"[T]he IRS/Treasury published final rules addressing how employers that fund health and welfare benefits through a VEBA must calculate the VEBA's UBTI.... The final rules largely mirror proposed UBTI rules the IRS issued in 2014... Rev. Proc. 2020-3 [is the] annual listing of areas where the IRS will not consider private letter rulings. Unfortunately, the IRS added to that list a ban on PLRs involving whether the 100% excise tax on reversions applies to transfers of assets between VEBAs and/or 'repurposing' assets within a single VEBA."