"[We] are writing to request that Treasury and the IRS publish official guidance ... affirming that the 100% excise tax under Internal Revenue Code Section 4976 does not apply to an employer's reallocation or repurposing of welfare benefit fund assets to provide other health and welfare benefits to employees and their beneficiaries.... Separately, we request guidance to address some confusion regarding the taxation of payments made under group fixed indemnity insurance offered by employers to support employers' ability to continue to offer these valued benefits."  MORE >>