Modified Accumulation Trusts For IRA or Other Qualified Plan Benefits at Death

Recent private letter rulings issued by the Internal Revenue Service have created concern among estate-planning attorneys regarding the best way to draft trusts that are intended as potential receptacles of IRA or other qualified plan beneifts upon the death of the participant. This concern stems from the fact that, unless the trust is properly drafted, it won't be possible to stretch out the payment of the retirement benefits over the trust beneficiary's lifetime.