Stretch IRA

I have a client that has 4 IRA’s of which are with the annuity carriers and one IRA is with Pershing. The client wants the contingent beneficiary to be a child’s separate trust contained within the clients revocable trust. The annuity carrier’s won’t allow sub trusts to be contingent beneficiaries, whereas Pershing will allow this.

The clients children are the contingent beneficiaries on each account. Could they transfer the death benefit proceeds to Pershing upon the clients demise, which would allow them to take the stretch distributions?

How can the client make his contingent beneficiary, his two daughters with the restrictions contained in the revocable trust?

Would it be taxable if it the beneficiary was set to go to a trust, which stated a new trust would be established for the benefit of the daughters and pay distributions to accordingly as stated in the trust? Is it possible to title a beneficiary IRA as a Trust beneficiary IRA?



Why not more the 4 annuity IRAs to Pershing (or any other non-annuity IRA custodian)?



Pershing does not custody IRA annuities, therefore the annuity contracts are in the single name of the client. This has been the issue. If it this was allowed at Pershing, it would then just go to the IRA, which allows the sub trust language. 



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