Trust as Beneficiary

A trust is a beneficiary of an IRA that is a look through trust. Owner was 88 at his passing. 3 individual beneficiaries of the trust.
Opening beneficiary IRAs for each beneficiary is desired. Custodian is looking for IRS regulation or PLR that permits this. Is this really necessary? Would the trust need to be terminated to do this?



  • The trust provisions must allow the trustee the discretion to terminate the trust or distribute trust assets (eg IRA) out of the trust in order for the custodian to accept assignment.  There have been many PLRs authorizing this, but some custodians do not cooperate, and they often stonewall the request. All we have is a chain of PLRs as the IRS has not issued direct guidance. It would be helpful if they did. The following link includes a recent PLR:
  • 202140011.pdf (irs.gov)


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