fiduciary reporting obligations in IRA-to-IRA transfers?

Assume these hypothetical facts to be true:

Participant dies before her RBD, leaving $300k IRA with no surviving named beneficiary. Default beneficiary under plan contract is SS (there is none), otherwise participant’s estate. Decedent’s pour-over will gives residue to trust, which in turn provides for outright distribution to two named beneficiaries.

Executor of deceased participant’s estate obtains state court order directing that estate-inherited IRA be transferred to a trust-inherited IRA (instead of distributed outright to trustee) and submits it to plan custodian, which complies.

Trustee prospectively directs plan custodian that upon creation of trust-inherited IRA, all proceeds are to be transferred immediately to two individual inherited IRAs for the two trust beneficiaries. Upon receipt of the state court order from the executor, plan custodian makes transfer to trust-inherited IRA, then transfers the proceeds of the trust-inherited IRA to two individual inherited IRAs in the name and under the social security numbers of the two trust beneficiaries. Each individual inherited IRA must be distributed entirely within 5 years from participant’s death. Each inherited IRA beneficiary pays income tax on distributions as they’re taken out.

Would either the executor or the trustee have any federal income tax reporting obligations with respect to these two IRA-to-IRA transfers, or is the only income tax reporting done by the two beneficiaries as they take distributions from their respective IRA?

If there were any federal income tax reporting requirement by the executor or the trustee, what would it be?



IRA direct transfers including those between decedent’s IRAs and beneficiary IRAs are not reportable. Only actual distributions are reportable. Therefore, there should be no 1099R or 5498, although the IRA custodian should be reporting the year end value of the IRA to the owner or beneficiary for RMD purposes. For income tax purposes then, only actual distributions will be reported to the recipient at the time.



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