IRS PLR On IRA Distributions to Multiple Beneficiaries from IRA Subacc

[Guest Edward McElroy]

Does anybody have any info regarding story in recent Wall Street Journal that IRS will release PLR that permits individual to set up a single IRA with different subaccounts (each with a different beneficiary)that would permit distributions to be made over each individual beneficiary's life expectancy. Thanks. Ed

[Guest Mary Ann]

I was told the PLR would be released August 6.

[Bruce Steiner]

This is nothing new. While they could have been clearer on this point, PLRs 9004042 and 9012009 suggest that this is the correct result.

This result makes sense (although that by itself is not necessarily determinative). There is no opportunity to gain an unfair advantage by treating each child's interest as a separate share. During the IRA owner's lifetime, the distributions are the same with respect to the share as to which each child is the beneficiary.

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Bruce Steiner, attorney

(212) 986-6000 (NY office)

(201) 862-1080 (NJ office)

also admitted in FL