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The audio portion of the conference may be accessed via the telephone or by using your computer's
speakers. Please refer to the instructions emailed to registrants for additional information. If you
have any questions, please contact Customer Service at 1-800-926-7926 ext. 10.
NOTE: If you are seeking CPE credit, you must listen via your computer — phone listening is no
longer permitted.
Structuring Special Needs Trusts as IRA
Beneficiaries: Avoiding Tax Traps in
Funding SNTs With Retirement Accounts
Today’s faculty features:
1pm Eastern | 12pm Central | 11am Mountain | 10am Pacific
TUESDAY, APRIL 19, 2016
Presenting a live 90-minute webinar with interactive Q&A
Elizabeth L. Gray, Principal, McCandlish Lillard, Fairfax, Va.
Scott K. Tippett, Attorney, The Tippett Law Firm, Oak Ridge, N.C.
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35.
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Why? SNTs avoid many of the costly mistakes people
make when planning for a child with special needs, such
as: • Disinheriting your child
• Relying on your other children to provide for child with
special needs
• Failing to provide privacy for the child with special needs
• Inheritances = over-resources
• Personal Injury settlements = over-resources/spending all
the funds at young age leaving child destitute
Special Needs Trusts
6
Criteria for eligibility for means-based benefits:
</= $2,000 Resources & Low Income
Options:
Accept the Money
Transfer penalty period issues
Spend down the Money
No Government benefits
Special Needs Trusts
7
Benefits of SNTS:
Protects eligibility for government benefits
i. Required to be disregarded as
available income and resources for
eligibility purposes
ii. Assets in SNT are NOT owned by the
beneficiary
iii. No transfer penalty period for funding
the SNT
Special Needs Trusts
8
Benefits of SNTS, continued:
• Provides for a higher quality of life
• Provides framework for care and
management of assets
• Allows the parent to express his/her
desires for child with special needs
(Memorandum of Intent)
• Protects assets from creditors and
predators
• Extends life of assets
Special Needs Trusts
9
2 Types of Special Needs Trusts
First-party Trust
Self-settled Trust
1396p(d)(4)(A) Trust
Payback Trust
Pooled or (d)(4)(C) Trust
(d)(4)(B) or Miller Trust
Special Needs Trusts
10
2 Types of Special Needs Trusts
Third-Party Trust
Family Funded Trust
Non-Payback Trust
Special Needs Trusts
11
1st Party Special Needs Trusts
• Protects the resources of individuals with disabilities without sacrificing
their government benefits;
• Must be in writing;
• Must be irrevocable;
• Must be Inter-Vivos.
Special Needs Trusts
12
1st Party Special Needs Trusts
A trust created for the sole benefit of an individual with disabilities
when such an individual is under the age of sixty-five (65).
Trust established by the individual’s parent, grandparent, legal
guardian or court; Assets not available;
Distributions not considered income;
No penalty period for SSI & Medicaid;
Special Needs Trusts
13
1st Party Special Needs Trusts
• Gifts to this type of trust should NOT be made by third parties!
• Sole Benefit Rule: the disabled individual must be the sole
beneficiary of the trust during his/her lifetime
• Payback Provision: funeral expenses cannot be paid after death;
Multiple states = pro rata
Special Needs Trusts
14
1st Party Special Needs Trusts
Why do it?
• Reimbursement is only for Medicaid, not all public benefits
• Reimbursement is based on the actual Medicaid expenditures, not
prevailing market costs
• No interest
• Some services not covered by Medicaid
Special Needs Trusts
15
1st Party Special Needs Trusts
Please see the Fact Guide for National Trust Training
Special Needs Trusts
16
3rd-Party Special Needs Trusts
• Can direct corpus at death of the beneficiary to any individual (no
payback requirement!)
• Not described in any federal statute
• Designed to supplement, rather than supplant, government benefits
for which the individual is otherwise eligible
Special Needs Trusts
17
3rd-Party Special Needs Trusts
Why do it?
• Improves the quality of life of an individual with disabilities
• Medicaid has no right of recovery/No payback requirement
• Can be Inter-Vivos or Testamentary
• Can be for the benefit of an individual of any age
• At death of the beneficiary, any remaining money can go to other
family members
Special Needs Trusts
18
Drafting Practices & Funding the Trust
1. Where the trust is being established by a parent or
grandparent, the parent/grandparent MUST execute the
trust and SEED the trust:
Initial funding MUST be from the parent/grandparent
and NOT the beneficiary
2. Where the trust is being established by a court the order
MUST establish and direct the transfer of the beneficiary’s
assets.
Special Needs Trusts
19
Drafting Practices & Funding the Trust, continued
3. In defining the term “special needs” for distribution
purposes, SNT attorneys have traditionally included a
list of specific distributions that could be made from the
trust. This “laundry list” has proven problematic when it
includes items which Social Security later deems
improper.
Special Needs Trusts
20
Drafting Practices & Funding the Trust, continued
4. A 3rd party special needs trust must be irrevocable
to the beneficiary (POMS Rule). It was believed
that this required the trust be initially irrevocable,
but today we know that a revocable 3rd party SNT
is allowed so long as the beneficiary cannot have
access to the trust assets.
5. Even when the trust converts to irrevocable, needs
to include flexibility:
• Trust Protector
• Trust Advisory Committee
• Trustee
Special Needs Trusts
21
Drafting Practices & Funding the Trust, continued
4. A 3rd party special needs trust must be irrevocable
to the beneficiary (POMS Rule). It was believed
that this required the trust be initially irrevocable,
but today we know that a revocable 3rd party SNT
is allowed so long as the beneficiary cannot have
access to the trust assets.
5. Even when the trust converts to irrevocable, needs
to include flexibility:
• Trust Protector
• Trust Advisory Committee
• Trustee
Special Needs Trusts
22
Drafting Practices & Funding the Trust, continued
6. The advantages of the trust being revocable to the
grantor:
• Changes can easily be made
• No tax return
• Assets – if any are taxed to the grantor
• Assets get a step up in basis upon the death of the
grantor – Example – trust holding real estate
Special Needs Trusts
23
Drafting Practices & Funding the Trust, continued
6. IRA Distributions to SNT
• Accumulation Language
• Not Conduit Language
7. Crummy Powers vs. Cristofani Powers
8. ABLE Accounts together with SNTs
Special Needs Trusts
24
Drafting Practices & Funding the Trust, continued
9. The drafter of a first-party SNT should:
• immediately report the creation and funding of the
trust to the SSA and local Medicaid eligibility office
or make sure that he or she documents in writing
that he or she has educated the trustee and
beneficiary about these rules, and
• designate professional trustees who know the SSI,
Medicaid and Section 8 housing distribution rules,
or document in writing that he or she has educated
the trustee about these rules.
Special Needs Trusts
25
Drafting Practices & Funding the Trust, continued
10.With the passage of the National Defense
Authorization Act of 2015, Congress has, for the
first time, allowed military members to name
special needs trusts as beneficiaries of Survivor
Benefit Plans (SBP). This means that military
families will finally be able to direct SBPs to their
children with special needs without compromising
the childrens’ ability to access government
disability and medical benefits.
Special Needs Trusts
26
27
Thank you
Elizabeth L. Gray, Esq.
McCandlish Lillard
11350 Random Hills Road, Suite 500
Fairfax, Virginia 22030
(703) 934-1104
Why are IRAs and Qualified Plans so
important? • Approximately $14 Trillion Dollars in Qualified Plans right now;
• Approximately $5 Trillion Dollars in IRAs;
• Second most popular account in households behind checking account;
• Comprise a large percentage of personal wealth;
• Special income tax, GST and estate tax considerations;
• Governed by federal and state law;
• Beneficiaries are determined by designation form provided by the trustee/custodian.
29
What Laws Govern IRAs?
• Federal Law:
– IRC §408 and §408A – Requirements
– IRC §401 – Distribution Rules
– Other Tax Law – Income Tax, Estate Tax, GST
– Bankruptcy Law
– Private Letter Rulings, Revenue Rulings, etc.
30
What Laws Govern IRAs (continued)?
• State Law:
– Uniform Principal and Income Act
– Guardianship
– Intestacy
– Elective Share, Common Law, Divorce
– Asset Protection
– Case Law
31
What Governs IRAs (continued)?
• IRA Agreement/Contract:
– Beneficiary default language (estate versus surviving
spouse)
– Per stirpes versus per capita
– Payout options during lifetime and post-mortem
– Governing law
– Arbitration clauses
32
Estate Tax Issues Post-Death Issues
Wills control probate assets
Trusts control trust assets
IRAs and qualified retirement plans are controlled by
beneficiary designation form or default provisions of
contract
33
Estate Tax Issues Post-Death Issues
Post-death RMDs based on whether “designated beneficiary” exists
• Only “individuals” with quantifiable life expectancy can be “designated beneficiaries”
• If trust qualifies, look through to underlying trust beneficiaries
Distribution out of trust to beneficiary does not make the beneficiary the “designated beneficiary”
34
Foundation Concepts Estate Tax Issues Post-Death Issues
Permissible “designated beneficiaries”: Individuals
• Spouse
• Child
• Grandchild
• Parent
• Brother/sister
• Niece/Nephew
• Neighbor
Certain trusts
35
Foundation Concepts Estate Tax Issues Post-Death Issues
Death before age 70½
Five-year rule
Exceptions to the five-year rule
Delayed distributions – spousal beneficiary
Spousal beneficiary – special trust problem
Death after age 70½
Life expectancy distributions if you have a designated beneficiary
Distributions must begin by December 31st of the year after death
Year of death distribution – life expectancy of IRA owner
36
Life Expectancy
Rule
Five-Year Rule
Death Before Required
Beginning Date
Death On or After Required
Beginning Date
Designated
Beneficiary
Non-
Designated
Beneficiary
“Ghost” Life
Expectancy Rule
Foundation Concepts
Life Expectancy
Rule
Estate Tax Issues Post-Death Issues
37
IRAs Payable to Trusts Advantages of Using a Trust
Spendthrift protection
Creditor protection
Divorce protection
Special needs
Investment management
Estate planning
“Dead-hand” control
38
Advantages of IRA Trusts
• PLR 201021038 shows how the typical provisions of a family revocable trust, inserted to obtain maximum flexibility, can defeat the Participant’s goal to stretch the IRA.
• PLR 201203033 shows what must be addressed to enable a family trust to qualify as a conduit trust to permit a spousal rollover and permit children to transfer their shares to inherited IRAs. This PLR also discusses the use of a disclaimer preserve the “stretch-out” of RMDs over a beneficiary’s life expectancy. This PLR provides a good road map for cleaning up a problem trust.
• PLR 201210045 reinforces the necessity to comply with the “separate account” rule when naming of the beneficiaries of an individual’s IRA account.
• PLR 201203033 shows how retirement benefits payable to a trust can qualify for the stretch out notwithstanding a broad power of appointment exercisable in favor of a class of permissible appointees, along with a charity as the ultimate beneficiary.
• Can a trust taxed as a grantor trust for income tax purposes be an IRA beneficiary? PLRs 200620025 (okay to transfer inherited IRA to a special needs trust) and PLR 200826008 (okay to transfer minor’s beneficiary share of decedent’s IRA to a grantor trust) say yes, but…
• PLR 201117042 says no when the Participant wanted to transfer his IRA to a special needs trust that was a grantor trust for income tax purposes
IRAs Payable to Trusts Disadvantages of Using a Trust
Trust tax rates
Legal and trustee fees
Trust income tax returns
• 1041
• 1099
• K-1
Greater complexity
40
IRA distributions over the
life expectancy of the oldest
beneficiary
Trust
IRA Beneficiary
Designation Form
Spouse
Children
IRAs Payable to Trusts Naming a Trust as a Beneficiary of an IRA
41
2. Trust is irrevocable upon death of owner
− Treas. Reg. § 1.401(a)(9)-4, Q&A 5(b)(2)
3. Beneficiaries of the trust are identifiable from the trust instrument − Treas. Reg. § 1.401(a)(9)-4, Q&A 5(b)(3)
4. Documentation requirement is satisfied − Treas. Reg. § 1.401(a)(9)-4, Q&A 5(b)(4)
IRAs Payable to Trusts Naming a Trust as a Beneficiary of an IRA
Four Requirements
1. Trust is valid under state law − Treas. Reg. § 1.401(a)(9)-4, Q&A 5(b)(1)
42
IRAs Payable to Trusts Naming a Trust as a Beneficiary of an IRA
Types of “IRA Trusts”
Conduit trusts
A trust in which all distributions (RMDs and any other
distributions/withdrawals) from the IRA are required to be
distributed to or for the benefit of the trust beneficiary,
and cannot be accumulated by the trustee
Accumulation trusts
A trust in which distributions from the IRA are allowed to
accumulate within the trust
Stronger asset protection than a conduit trust
43
Conduit Trusts as SNTs
Conduit Trusts
-- Conduit beneficiary could potentially receive the entire IRA balance if the beneficiary lives to full life expectancy.
-- Contingent trust beneficiaries (charities, the conduit bene’s spouse, siblings, issue, appointees under a testamentary general or limited power of appointment are “mere potential successors” and do not have to be counted.
Conduit Trusts as SNTs
• If the trust document allows the trustee to
withdraw more than the RMDs, then any of
those withdrawals must also be distributed to
or for the benefit of the conduit trust
beneficiary.
Mother
Age 80
Trust
Discretionary
Distributions, but no
less than total
withdrawals from IRA
Entire Trust outright
upon Grandchildren
reaching age 30
If Grandchildren die
before reaching age 30
Mother is not
“countable” for
determining
applicable life
expectancy
Treas. Reg. §
1.401(a)(9)-5 Q&A 7
Child –
age 30
Child –
age 30
IRA
IRAs Payable to Conduit Trusts Naming a Trust as a Beneficiary of an IRA
Conduit Trust – Example
46
Conduit Trusts as SNTs
Is a conduit trust appropriate for a
special needs child who is receiving
and depends upon means tested
government benefits (SSI and
Medicaid)?
47
Conduit Trusts as SNTs
Generally NO.
Because the RMDs and other distributions from
the IRA must be distributed to or for the benefit
of the beneficiary of a conduit trust, the conduit
trust distributions would likely cause the special
needs child to lose his or her benefits.
48
Conduit Trusts as SNTs
If loss of means tested benefits is not an issue, a
conduit trust could be used to insure the benefits
are paid over the special needs beneficiary’s life
expectancy.
49
Conduit Trusts as SNTs
In this case, trust should be drafted to give the trustee broad powers to invade the IRA for changing medical, psychological, and social needs of the special needs beneficiary.
Trust should also give the trustee power to spend down the assets, as opposed to continuing the stretch-out, if the receipt of SSI and Medicaid benefits would be of greater benefit to the special needs beneficiary.
50
Conduit Trusts as SNTs
A Better Approach Using Conduit Trusts as SNTs?
Combine the conduit trust as SNT with a third-party created and funded SNT.
If spend down of the Conduit-SNT is needed or simply occurs, the third-party SNT, which would NOT hold retirement account assets, will permit the special needs beneficiary to qualify for and receive SSI and Medicaid.
51
IRAs Payable to Accumulation Trusts Naming a Trust as a Beneficiary of an IRA
Accumulation Trust
An “accumulation trust” is any trust that is not a conduit
trust, which means the trustee has the power to
“accumulate” plan distributions within the trust.
As the name implies, an accumulation trust permits the
trustee to accumulate (not distribute) RMDs and other
withdrawals to the beneficiaries.
Trustee still must be able to look through the trust and
determine which beneficiaries will receive the retirement
account proceeds.
52
Accumulation Trusts as SNTs
– The key issue in analyzing an accumulation trust is
to determine which beneficiaries are “countable.”
- All beneficiaries are countable unless such
beneficiary is deemed to be a “mere
potential successor” beneficiary.
53
Accumulation Trusts as SNTs
What if the accumulation trust is a dynasty trust so that the trust does not distribute assets outright to a beneficiary living at the account holder’s death?
Typical dynasty trust default contingent beneficiaries are charities or the grantor’s heirs at law.
These default contingent beneficiaries would probably have to be included in determining whether the trust qualifies as a see-through trust and whether the default contingent beneficiaries will be treated as “designated beneficiaries.”
54
Accumulation Trusts as SNTs
Problems: - Charity as Contingent Bene.
If a charity is named as a default contingent
beneficiary, the trust will fail as a see-through
trust because the charity is not an individual,
unless the trustee can convince the contingent
beneficiary charity to disclaim its interest by
9/30 of the year following the year of the
participant’s death.
See PLR 9820021.
55
Accumulation Trusts as SNTs
Problems: - Heirs at Law as Contingent Bene
If the account holder’s heirs at law are much
older than the intended trust beneficiary, the
payout could be over a much shorter time frame.
Recall, unless the separate share rule applies,
you must use the oldest beneficiary as the
measuring life.
56
IRA
Sister
Age 67
Grandchildren
Trust
Discretionary
Distributions
Grandchildren
Entire Trust outright
upon Grandchildren
reaching age 30
If Grandchildren die
before reaching age 30
Sister measuring life
for determining
required minimum
distributions
Facts same as PLR
200228025
IRAs Payable to Accumulation Trusts Naming a Trust as a Beneficiary of an IRA
Accumulation Trust – Example
57
Accumulation Trusts
as SNTs – Advantages
• Issues With Accumulation Trusts
• Some or all of the potential remainder beneficiaries are not
disregarded for RMD purposes, which means an accumulation
trust should not include remainder beneficiaries older than the
lifetime beneficiary.
• Contingent beneficiaries may not include one or more charities
or an undetermined surviving spouse, otherwise it may be
deemed to have no designated oldest beneficiary.
• An accumulation trust may not include a limited testamentary
power of appointment in favor of charities, surviving spouses,
or older beneficiaries.
58
Accumulation Trusts as SNTs
Accumulation trusts, where drafted as a third-party created and funded SNT usually work well for a special needs beneficiary because:
The trustee can be given sole discretion to accumulate or distribute income or principal over the special needs beneficiary’s lifetime in a manner that would not cause the loss or reduction of means tested benefits.
59
Accumulation Trusts
as SNTs-Advantages
• Modified Accumulation Trust*
• Features of a Modified Accumulation Trust
• An A share and a B share; the A share receives benefits from
all qualified plans and IRAs, the B share is everything else
• Testamentary appointees of the A share are limited to
descendants of the primary current beneficiary in the same or
younger generation as the primary current beneficiary.
• If surviving spouse is permitted appointee of the A share,
specify that surviving spouse is no older than a designated
number of years older than the primary beneficiary.
60
Accumulation Trusts
as SNTs-Advantages
• Modified Accumulation Trust
• Provides that certain remaindermen are
deemed to be predeceased in the event the
current beneficiary dies before the trust
terminates. These remindermen can receive a
preferential distribution of the B share. Can
provide for an adjustment mechanism to offset
any difference in tax consequences between
the A share and B share beneficiaries.
61
Accumulation Trusts as SNTs
• Solution to This Varied Landscape?
• An accumulation trust or modified accumulation
trust.
• With the power to accumulate, the trustee can elect to
accumulate the retirement benefits instead of passing
the benefits out to the beneficiary.
• Possible to draft trust that starts out as a conduit trust,
but a triggering event turns it into an accumulation
trust.
62
Accumulation Trusts as SNTs
Drafting Tips:
1. DO name as remainder beneficiaries, only those individuals who are younger or close in age to the special needs beneficiary.
2. DO NOT name a charity as a beneficiary or include a GPOA that can be exercised in favor of the beneficiary’s estate or another entity.
3. DO NOT give the special needs beneficiary a GPOA because that may cause the entire IRA as an available asset, thereby causing a reduction or loss of means tested benefits.
4. DO NOT give the special needs beneficiary a limited power of appointment without restricting the power to be exercised only in favor of appointees younger than the special needs beneficiary as of the date of the account owner’s death.
63
Other Drafting Considerations
• Revocable vs. Irrevocable
– Revocable
• Allows easy changes to trust
• May open IRA to account owner’s creditors at death
(Commerce Bank v. Bolander, 2007 WL 1041760, Kan.
App. 2007) – UTC state
– Irrevocable
• May not be changed, but a new trust can be drafted and
the beneficiary designation simply changed
• Protects against Commerce Bank case problem
64
Separate Share Rule
• Payable to single trust
• No separate shares identified in the beneficiary designation form
• IRA paid over oldest life expectancy
Paying IRAs to Trusts
65
Separate Share Rule
• IRA payable to multiple trusts
• Each trust named in
beneficiary designation form
• IRA paid over each separate trust beneficiary’s life expectancy
Paying IRAs to Trusts
66
• Ruling 1: Each Beneficiary’s Trust Share Qualified for Maximum Stretch-out.
– Upon the death of the Settlor, the IRA stand-alone trust creates separate shares for each beneficiary (in this case, separate shares for 9 beneficiaries), each trust share “treated effective ab initio to the date of the Decedent’s death” and each share functioned as a “separate and distinct trust” for the beneficiary.
– The beneficiary designation form named each separate share as a primary beneficiary of the IRA.
– Before the December 31st deadline, the IRA was divided into separate accounts for each share.
– Held: Separate account treatment permitted; MRD of the IRA for each separate trust share measured by the lifetime of its sole beneficiary for whom the share was created.
Separate Share Rule
PLR 200537044
Paying IRAs to Trusts
67
• Ruling 2: Allowance of One-Time “Toggle” Between Accumulation and Conduit Trust.
– Each separate share in the IRA stand-alone trust had language structuring the separate share as a conduit trust.
– The trust provided for an independent 3rd party, as “trust protector” to transform each sub-trust to an accumulation trust in the protector’s sole discretion by voiding the conduit provisions ab initio.
– Trust Protector had the authority to limit the initial trust beneficiary ab initio.
– After Participant’s date of death, Trust Protector exercised “toggle” and converted one share to an accumulation trust.
– Held: Each share can use that the life expectancy of its initial beneficiary to measure the MRD for that share.
Separate Share Rule PLR 200537044
Paying IRAs to Trusts
68
• Ruling 3: Payment of Expenses from IRA not considered an accumulation.
– The trust provided that “Trust expenses may be deducted prior to any such payment to or for the benefit of the beneficiary of the trust share if the deduction does not disqualify the status of the trust as a conduit trust. This paragraph may be rendered void, ab initio, by the Trust Protector. . .”
– Held: Each share can use that the life expectancy of its initial beneficiary to measure the MRD for that share.
– Why? Even with the deduction for payment of trust expenses, no amounts distributed to the trust during the beneficiary’s lifetime would be accumulated in the trust, and thus would not be kept in the trust for the benefit of any future beneficiaries. Treas. Reg. § 1.401(a)(9)-5 Q&A 7(c)(3), Example 2.
Separate Share Rule
PLR 200537044
Paying IRAs to Trusts
69
• Ruling 4: The trust assets will not be included in the estate of the primary beneficiary of a share upon that beneficiary’s death.
– Each trust share would accumulate the net income of the trust, and distributions of income and principal could distribute accumulated income and principal to the primary beneficiary for his or her health, education, maintenance and support only.
– The document did not grant any beneficiary a general power of appointment over his or her share.
– Held: The provisions of the trust could not result in estate inclusion for the estate of a primary beneficiary upon his death.
Separate Share Rule PLR 200537044
Paying IRAs to Trusts
70
Reforming Beneficiary Designations
PLR 200616039-41
• Daughter's life expectancy could be used. Even though no
contingent beneficiaries were named, court reformed beneficiary
designation to name daughters as contingent beneficiaries of IRA.
• IRS is currently rethinking this position.
Paying IRAs to Trusts
71
• Service ruled that the retroactive reformation of a trust would not be
respected for purposes of section 401(a)(9) and the related regulations.
• The trustee reformed the trust pursuant to a state court order to remove
charities under a limited power of appointment granted to first tier
beneficiaries.
• The adverse ruling means the trust was not treated as a “designated
beneficiary trust” (“DBT”) and that the trust beneficiary’s life expectancy
could not be used for determining required minimum distributions.
Reforming Beneficiary Designations
PLR 201021038
Paying IRAs to Trusts
72
Resources on IRA Rules
• Life and Death Planning for Retirement
Benefits by Natalie Choate 2011- 7th Ed.
www.ataxplan.com
• www.irahelp.com (Ed Slott, CPA)
• Robert Keebler, CPA
www.keeblerandassociates.com
• IRS Publication 590
http://www.irs.gov/pub/irs-pdf/p590.pdf
73
Resources on Estate Planning for
Special Needs Beneficiaries
• Estate Planning for a Family with a Special
Needs Child, Sebastian V. Grassi, Jr., Probate
and Property (July/August 2009)
• Estate Planning for a Family with a Special
Needs Child: Part 2 – Trusts as Beneficiaries
of Retirement Plan Benefits, Sebastian V.
Grassi and Nancy H. Welber, Jr., Probate and
Property (September/October 2009)
74
Contact Information:
Scott K. Tippett*
The Tippett Law Firm, PLLC
T: (336) 643-044
F:(336) 458-3215
Thank you for attending!
* Admitted in Georgia, North Carolina, and United States Tax Court
75