28 June 1995 CTF Roundtable, 9508496 - NON-FUNDED SUPPLEMENTAL PENSION PLANS -- summary under Refundable Tax

"Where a trust governed by an RCA obtains an LOC [Letter of Credit] and, in addition to the fee charged by the bank to the trust, the employer must pledge assets, the amount of contributions under the RCA, would, in our view, be equal to the lesser of the total of fair market values of both the LOC and the pledged assets and the face amount of the LOC." "In addition to the above, a contractual obligation by the company to prepay the amount of the LOC to the bank on demand would not constitute a contribution to the RCA in and of itself".