Adjusting IRAs' Investment ReturnsAdjusting IRAs' Investment Returns
In Revenue Ruling 2006-26,1 the Internal Revenue Service focused on two fiduciary accounting rules involving payments from an individual retirement account (IRA) to a trust intended to qualify for the estate tax marital deduction. Both rules came from the latest version of the Uniform Principal and Income Act published in 1997 and amended in 2000 (UPIA).2 The revenue ruling dealt with the rules' impact
David S. Sennett
In Revenue Ruling 2006-26,1 the Internal Revenue Service focused on two fiduciary accounting rules involving payments from an individual retirement account (IRA) to a trust intended to qualify for the estate tax marital deduction. Both rules came from the latest version of the Uniform Principal and Income Act published in 1997 and amended in 2000 (UPIA).2 The revenue ruling dealt with the rules' impact on the surviving spouse's annual entitlement to all of the IRA's net accounting income (sometimes referred to as “income”), a key requirement for obtaining the qualified terminable interest property (QTIP) marital deduction.
The IRS dismissed reliance on the first rule, UPIA Section 409, as failing to satisfy the surviving s...
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