Drafting IRA Beneficiary "See-Through" Trust Provisions

Meeting Complex IRS Rules to Qualify a Trust as a Conduit Trust or an Accumulation Trust

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
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Conducted on Tuesday, October 26, 2021

Recorded event now available

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Course Materials

This CLE course will provide estate planning counsel with detailed guidance on drafting "see-through" trusts that qualify as IRA beneficiaries under IRS regulations. The panel will explain provisions governing both "conduit trusts" and "accumulation trusts" and offer sample language for both trusts that will meet IRS standards.


A valuable tool for protecting IRA assets as a component of estate planning is using a trust as an IRA beneficiary. These "see-through" trusts can provide valuable flexibility in a comprehensive estate plan and carry both income tax consequences and stringent IRS requirements for qualification. Estate planning counsel must know the detailed IRS rules in drafting these "see-through" trusts to meet RMDs and income accumulation requirements.

IRA beneficiary trusts generally come in two types: "conduit trusts" and "accumulation trusts." Specific requirements mark conduit trusts as to calculating RMDs over the lifetime of qualified designated beneficiaries. Importantly, IRA beneficiary trusts are drafted as trusts (whether QTIP trusts or any other) valid under state law but contain specific language and provisions that qualify the trust for see-through treatment.

Whether estate counsel is drafting a trust to function as a conduit trust or an accumulation trust, practitioners must know the rules and required language to avoid severe tax consequences.

Listen as our experienced panel provides detailed guidance, including sample language, to help you master the intricacies of drafting see-through IRA beneficiary trusts.



  1. Trusts as beneficiaries of IRA
  2. Conduit vs. accumulation trust
  3. DNI impact and considerations
  4. Drafting provisions for conduit trusts
  5. Drafting provisions for accumulation trusts


The panel will review these and other relevant issues:

  • Impact of the SECURE Act and other regulations
  • Income tax considerations in utilizing a see-through trust
  • What provisions must be included in trust language for a trust to qualify for see-through treatment as either a conduit trust or an accumulation trust
  • Factors to consider when drafting a QTIP trust as an IRA beneficiary trust


Blumberg, Joseph
Joseph N. (Joe) Blumberg

Senior Vice President, Senior Trust Advisor
Northern Trust Wealth Management

Mr. Blumberg works with clients to proactively solve problems related to wealth management and trust...  |  Read More

Shoff, Nathan
Nathan Shoff

Lacy Katzen

Mr. Shoff compassionately assists clients facing the inevitable challenges of aging, sickness, and death by counseling...  |  Read More

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