Trust as IRA Beneficiary

In order to treat trust beneficiaries as if they had been named directly as designated beneficiaries, Reg. 1.401(a)(9)-4, Q&As 5 and 6 require the IRA Administrator be provided a copy of the trust instrument or a list of beneficiaries, etc.

When an IRA does not have an Administrator, who must be provided with the above documentation? Must it go to the custodian within the required time period or as long as the trustee of the trust has the documentation, it is considered “delivered” to the Administrator (trustee)?



The IRS Regs are written for qualified plans. When the plan is an IRA, the IRA owner is substituted for the employee and the IRA custodian is substituted for the plan administrator. Therefore, the trust info must be provided to the IRA custodian by 10/31 of the year following the year of IRA owner’s death.

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