"The IRS National Office recently released a legal memorandum ... relating to pre-funding post-retirement medical benefits in a welfare benefit fund.... [T]he memorandum holds that funding an allowable post-retirement medical reserve may NOT take into account periods of coverage before an actual severance from employment.... The position in this legal memo is not particularly surprising given the language of the statute. But, it potentially reflects a more restrictive position than the IRS has previously followed in rulings describing allowable funding policies for Code section 401(h) post-retirement medical benefit funding."  MORE >>