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Internal Revenue Service <br />Index Number: 115.02-00 <br />City = <br />Trust = <br />State = <br />Dear <br />Department of the Treasury <br />Washington, DC 20224 <br />Contact Person: <br />Telephone Number: <br />In Reference to: <br />CC:DOM:FI&P:2 PLR-116685-99 <br />Date: <br />December 28, 1999 <br />This is in response to a letter dated October 12, 1999, and <br />prior correspondence, requesting a private letter ruling that <br />Trust is an integral part of City. <br />FACTS <br />City is a political subdivision of State. City currently <br />maintains one or more post -retirement welfare benefit plans <br />(collectively, the "Plan") that provide its eligible employees <br />("Participants") and their beneficiaries ("Beneficiaries") with <br />life, sickness, medical, disability, severance and other similar <br />benefits through insurance and self -funded reimbursement plans. <br />City intends to establish Trust to hold assets and income of <br />the Plan for the exclusive benefit of Participants and their <br />Beneficiaries. <br />Trust's Declaration defines "Beneficiaries" tc include a <br />Participant's spouse, any child of the Participant or the <br />Participant's spouse who iS a m1nOr Or a StllClent Within `he <br />meaning of section. 151(c)(4) of the Internal Revenue Code, anv <br />other minor child residing with the Participant, and any other <br />individual who is a person described in section 152(a) of the <br />Code. Death benefits may be provided to anv Beneficiar;r <br />designated by a Participant under the terms of a death benefit <br />program or an insurance contact form na part or `�� D -_•_ct <br />03/2000 <br />10 <br />