In PLR 201927009, the IRS ruled that an estate could transfer, via trustee-to-trustee transfers, amounts from one IRA to two inherited IRAs to separate the interests of two children. The IRS ruled that
- such transfers do not result in distributions under Code Sec. 408(d)(1)
- such transfers do not result in rollovers under Code Sec. 408(d)(3)
- the inherited IRAs created by means of the trustee-to-trustee transfers, which would be maintained in the name of the two children respectively, would constitute inherited IRAs as such term is defined in Code Sec. 408(d)(3)(C).
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal..