In General

ID: CCA_2012022311414856 Number: 201220031
Release Date: 5/18/2012
Office: ---
UILC: 35.01-00
From: ---
Sent: Thursday, February 23, 2012 11:41:53 AM
To: ---
Cc: ---
Subject: RE: "Retroactive" PBGC payments for the HCTC
If this is the only issue, I’d grant him the credit. (Some other possible issues include whether he in --- was at least age 55, whether he was not receiving Medicare or employer-subsidized coverage, and whether his health coverage was qualified health insurance.) The statute requires that he receive payments from the PBGC "for" a month, not "in" or "during" a month. A retroactive payment applied to a month is a payment "for" that month.