IRS Rejects UPIA 10 Percent Rule

If an asset is to qualify for the federal estate tax marital deduction as qualified terminal interest property (QTIP), the decedent's surviving spouse must be entitled to all of the income for life from such asset.1 When an individual retirement account (IRA)2 is payable to a marital trust as beneficiary, what is the the spouse must be entitled to with respect to the IRA? The Internal Revenue Service

If an asset is to qualify for the federal estate tax marital deduction as qualified terminal interest property (QTIP), the decedent's surviving spouse must be entitled to all of the income for life from such asset.1 When an individual retirement account (IRA)2 is payable to a marital trust as beneficiary, what is the “income” the spouse must be entitled to with respect to the IRA? The Internal Revenue Service has answered this question in Revenue Ruling 2006-26,3

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