IRA distributed to a CRT

What would be the effect on the IRD if distributed an IRA to a CRT?



Do you mean IRD or RMD?



Income in REspect of a Decedant



The income beneficiaries of the CRT would owe taxes on the IRD from IRA earnings, but the charity would receive whatever is left tax free.

I imagine that the income beneficiaries would receive a potential IRD misc itemized deduction if federal estate taxes were paid.



Actually the Regs 20.2031-7(d) say the income beneficiaries would have income on gain (IRD) less the value of the annuity since the trust would have to be a CRAT or CRUT.



I am somewhat confused. If the IRA bene is the CRT, why would the income benes be taxed at the time of death on the IRD? The CRT pays no taxes, however would track the ordinary income so that as the benes received their annuity payments, the OI would simply take precedence over Cap Gains, Tax-Free and Cost basis.



Another thought. If the CRT was a NIMCRUT that owed back payments, I could see the IRA DB might force out income to the extent of the make-up.



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