ID: Office: UILC: CCA_2009042309111441 ---------------------------- 419.03-00 Number: 200922038 Release Date: 5/29/2009 From: ------------------ Sent: Thursday, April 23, 2009 9:11:16 AM To: ----------------------------------------------- Cc: ---------- ---------------- Subject: RE: VEBA The deduction is under section 419 regardless of whether the trust is a VEBA. The def’n of W elfare Benefit Fund in 419(e) includes a non-exempt trust. We sent ------- some language he can use – we would refer to the t rust by name, and not refer to it as a VEBA. Remember that ------------- is a different taxpayer, and we cannot give them information on the status of the trust/purported VEBA – we cannot imply that the trust is not a VEBA; doesn’t matter for our purposes.