GM also announced that, subject to the completion of the offering, it intends to repurchase from the underwriters a portion of the 40 million shares of common stock being offered having an aggregate value of approximately $100 million at a price per share equal to the price per share that the underwriters pay to the VEBA
Trust in the offering.
trust is established under section 501(c)(9) of the Internal Revenue Code as an employee association to provide for designated benefits.
While Peabody has met its obligations under this agreement, Patriot breached the agreement, which left unclear Peabody's ongoing funding requirements to the VEBA
," it said.
Chrysler chairman and CEO, Sergio Marchionne, said, 'This transaction brings to a successful and earlier than anticipated conclusion, the process that led the US and Canadian governments, the UAW and the VEBA
, together with Fiat, to take on the task of re-establishing Chrysler as a viable automotive enterprise.
Country: USASector: Motor VehiclesTarget: Chrysler Group LLCBuyer: Fiat SpAVendor: VEBAType: Corporate acquisition, MergerStatus: BiddingComment: VEBA
reportedly seeks to get USD6bn for its stake.
Fiat is expected to continue talks with VEBA
to acquire the remaining 25 percent not covered by the call options.
Membership of a VEBA
must consist of individuals who are employees and have an employment-related common bond such as a common employer, coverage under one or more collective bargaining agreements or membership in a labor union.
Code [section] 512(a)(3)(B) provides that a VEBA
may exclude from taxable income member contributions plus amounts set aside for payment of benefits and expenses.
Benefit security for individual employees is enhanced by using a VEBA
, since there is an irrevocable trust for the exclusive benefit of employees and protection against reversion of funds to the employer.
tax code since the 1920s, the VEBA
has traditionally been used by large corporations as a way to offset costs in providing benefits to employees.
Almost any business can establish a VEBA
for its employees, including owner-employees.
Since deemed unrelated income of a welfare benefit trust is defined in section 419A(g)(2) as the amount that would have been in the fund's UBTI under section 512(a)(3) if the fund were a VEBA
, and there is no indication that a different aggregation rule wax intended for non exempt welfare benefit funds than for VEBAs
, we infer that Congress was assuming that an employer could elect to aggregate two or more VEBAs
, or one or more VEBAs
, and one or more non-exempt funds under section 419A(h)(1)(B) for purposes of calculating UBTI under section 512(a)(3).