"We again write to recommend that Treasury and IRS publish official guidance confirming that the 100% excise tax on reversions under Section 4976 of the Internal Revenue Code ... does not apply when an employer 'repurposes' surplus retiree benefit assets in a welfare benefit fund to provide other health and welfare benefits, including to active employees.... [T]here are compelling policy reasons to issue guidance to allow the repurposing of such assets -- and no apparent policy or legal reasons to continue to place billions of dollars of tax-deferred welfare benefit fund assets in 'tax limbo.' "  MORE >>