I just received a response from Ameneh Bordi at Kirkland and Ellis regarding our HCTC question. She writes...
Avaya did reach out to PBGC in regard to this question, but did not receive a response. Alight (Avaya’s benefit’s vendor) will be issuing tax forms for the period prior to the final transition -- but it may be possible for you to reach out to PBGC and request they provide a letter stating that Alight was issuing tax forms on PBGC’s behalf due to the transition for the first half of 2018.
I'm not confident that anyone at the PBGC will respond to us and provide a letter as described by Ms. Bordi; but, I will try.
John Lawrence
Avaya Retiree 2001