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IRA Beneficiary Distributions to CharityIRA Beneficiary Distributions to Charity

Getting a private letter ruling turns into a Kafkaesque experience.

Jonathan Tidd

September 24, 2020

16 Min Read
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In October 2019, the Internal Revenue Service issued Private Letter Ruling 201943020 (July 25, 2019), which concerns an individual retirement account left to a charity client of mine.

The amount remaining in the IRA was about $30,000, small enough for the client to decide to seek a PLR as it was willing to wait to get the distribution. Getting a PLR would delay a beneficiary distribution but that was tolerable for my client from a financial standpoint. 

Custodian Insists on Inherited IRA

The custodian of the IRA is a major U.S. financial institution. The custodian insisted that my client set up what the custodian calls an “inherited IRA.” The custodian would make the beneficiary distribution only to the inherited IRA.  

The custodian stated ...

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About the Author

Jonathan Tidd

Jonathan G. Tidd  is an attorney whose practice is limited to advising charitable organizations on gift planning issues.  He has been admitted by exam to the Connecticut, Illinois, Indiana, and New York Bars.  His clients include a wide range of educational, health care, arts, human rights and social service organizations.  His articles on charitable gift planning have appeared in THE JOURNAL OF TAXATION; ESTATE PLANNING; and other professional journals.  His office is in West Simsbury, Connecticut.