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Deathbed Roth Conversions and the IRD Deduction
Michael Kitces in Nerd's Eye View Link to more items from this source
July 15, 2015
"[W]hile the [income in respect of a decedent (IRD)] deduction does shelter against Federal estate taxes, deathbed Roth conversions can still be relevant to protect against state estate taxes. Though in either case, the greatest driver of the outcome is not actually the IRD deduction or minimizing state estate taxes at all, but trying to shift the timing of when the IRA is recognized for tax purposes, so that the income taxes are paid at whichever rate is lower -- either the IRA owner now, or the rate the beneficiaries would pay by simply inheriting the pre-tax IRA and stretching it out in the future!"

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