qualified current retiree liabilities

(A)The term “qualified current retiree liabilities” means, with respect to any taxable year, the aggregate amounts (including administrative expenses) which would have been allowable as a deduction to the employer for such taxable year with respect to applicable health benefits and applicable life insurance benefits provided during such taxable year if— (i)such benefits were provided directly by the employer, and (ii)the employer used the cash receipts and disbursements method of accounting. (B)The amount determined under subparagraph (A) shall be reduced by the amount (determined separately for applicable health benefits and applicable life insurance benefits) which bears the same ratio to such amount as— (i)the value (as of the close of the plan year preceding the year of the qualified transfer) of the assets in all health benefits accounts or applicable life insurance accounts or welfare benefit funds (as defined in) set aside to pay for the qualified current retiree liability, bears to (ii)the present value of the qualified current retiree liabilities for all plan years (determined without regard to this subparagraph).

Source

26 USC § 420(e)(1)(A)


Scoping language

For purposes of this section
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