Treasury and IRS have just released the 2026-2027 Priority Guidance Plan.  The Plan lists 121 projects, but there are no surprises affecting employee benefits.

Fortunately, the Plan continues to list “Regulations Under Section 4976 relating to welfare benefit funds, including VEBAs.”  Hopefully this will be the year we get helpful guidance allowing surplus VEBA assets held for retiree medical benefits to be “repurposed” for active medical or other permissible benefits.  It has been 7 years since that area was added to the IRS “no rule” list.  It's definitely time to provide companies with much needed comfort that the 100% excise tax won't apply to straightforward repurposing transactions.