SNT as IRA Beneficiary

I apologize if anyone has already answered this, but I didn’t see it in the recent topics discussed. The question is, what are the withdrawal requirements of a Special Needs Trust as the beneficiary of an IRA inherited after the original owner was over age of RBD. As I understand it, the Special Needs Trust can essentially be distributed still as a stretch, even though the owner passed away after January 1st, 2020. That the distribution amount would be based on the age of the oldest special needs beneficiary, in this case just the one (or is it based on the oldest of all the beneficiaries of the original IRA? three individuals and the SNT?). In the case of a 1MM$ IRA like this, the distributions would likely kick the beneficiary off of state assistance if it was sent to her, but can the distributions be directed directly to the SNT and that way the individual never actually receives them? I appreciate any thoughts and input to clarify. The client seems under the impression that the SNT inherited IRA requires no RMDs, but I can’t seem to find any scenario where zero distributions are required.



  • The following assumes that this is a valid applicable multi beneficiary trust (AMBT) under the proposed Secure Act Regs and also qualifies for look through, that the separate accounts deadline is met, and that no beneficiary of the AMBT (SNT) can receive funds from the trust until after the death of the disabled trust beneficiary.
  • The disabled trust beneficiary is treated as an EDB, and annual RMDs from the inherited IRA will be based on the single LE of the disabled beneficiary. This applies whether the trust makes distributions out to the beneficiary or accumulates the distributions in the trust. However, accumulation of IRA distributions in the trust will be taxed at the higher trust tax rates.
  • SInce the above is subject to the separate account rules, I suggest that the IRA be partitioned now into one IRA for the 3 non disabled individuals, with the other IRA for the trust to inherit 100%. This will eliminate the possibility of the trust losing EDB status due to failure of the separate account deadline.

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