A
VEBA allows the employer a great deal of latitude in choosing plan benefits.
512(a)(3)(E)(i) provide that a
VEBA's income is exempt-function income (and, thus, not UBTI) only "to the extent that the total amount set aside in the
VEBA...as of the close of the taxable year...does not exceed the qualified asset account limit for such taxable year of the organization:" However, the court held, "the limit is on the amount of income that is still set aside at the end of the year, not to [sic] amounts that were set aside but were spent over the year's course." Thus, it held that the trust had no UBTI, because it spent all of its income during the year on administrative expenses.
The additional pounds 316 million was agreed by E.ON and BP after they sold
Veba Oel's upstream business to PetroCanada.
A
VEBA is a qualified welfare benefit plan that permits a business to make tax-deductible contributions to establish benefits for owners and employees.
In accordance with the IRC, the plan or
VEBA could net gains or losses generated by one investment fund against the gains or losses generated by another.
After bidding out health-care services and working with a voluntary employee beneficiary association (
VEBA) trust to engage in alternative investments and improve administration, Colorado Springs School District 11 has found a better approach to providing healthcare benefits.
The
VEBA entered into an insurance contract with an unrelated insurance company to cover the cost of providing these benefits.
Establishment of either an HSA or
VEBA by the sponsoring employer must be accompanied by a workplace policy that precludes deferral of vacation/sick days or the receipt of cash for unused vacation/sick days.
As part of the deal, Fiat North America LLC (FNA) paid USD1.75bn (EUR1.29bn) in cash to the
VEBA trust, using its existing cash resources.
Apart from the $3.65 billion, Fiat has agreed to pay
Veba $700 million in cash over four years starting from the date of completion of the deal.