Transferring income tax liability to beneficiaries of IRA trust while still alive

I am a 84-year-old widower with a large IRA. Assuming a reasonable growth it is possible that my estate will be more than $5 million around 2025. The named beneficiary of my IRA accounts is an IRA trust. This Trust is an accumulating (also called discretionary), spendthrift, see-through trust for non-eligible designated beneficiaries to hold distributions from my Roth IRA and traditional IRA accounts after my death. The beneficiaries of this IRA trust are the issues of my mother no matter what generation. Currently there are about 50 members to this class a beneficiary.

Since I am concerned about estate taxes after 2025, I would like to spend down my traditional IRA accounts. I can take a large distribution and then make gifts to the beneficiaries of the trust; however, I will incur substantial income tax with this large distribution.

Question: Is there a way to “pretend I am dead” and have this large distribution flow to the IRA trust and then be distributed to the 50 beneficiaries reporting this transaction on each beneficiaries K-1. This way the 50 beneficiaries would pay the income tax at a much lower rate.



No, there is no way to do that. But you might check with an estate attorney to determine if there is another way to at least partially accomplish your objectives. 

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