Unlocking Stretch IRA Opportunities with Subtrusts

June 4, 2025

The SECURE Act of 2019 reshaped how IRAs are inherited, ending the “stretch IRA” for most non-spouse beneficiaries. Instead of lifetime tax deferral, many heirs now face a 10-year window to fully distribute inherited retirement accounts — significantly accelerating taxes and reducing flexibility.


But recent IRS regulations have created a meaningful opportunity for proactive families: subtrusts that preserve stretch treatment for certain beneficiaries.


What’s New — and Why It Matters


Before the 2024 IRS guidance, naming a trust as the beneficiary of your IRA often meant everyone in the trust defaulted to the 10-Year Rule — even if some were eligible for more favorable treatment.


Now, if that trust splits into subtrusts upon death, each subtrust may apply its own distribution rules:


  • Eligible Designated Beneficiaries (EDBs) — like surviving spouses, chronically ill heirs, or minor children — can still stretch distributions over life expectancy.
  • Non-Eligible Designated Beneficiaries (NEDBs) — such as adult children — follow the 10-Year Rule.


This means estate plans can now better align tax treatment with each beneficiary’s unique needs.


Who Needs to Pay Attention?


This planning opportunity is especially relevant for:


  • Families who’ve named a trust as the IRA beneficiary
  • Parents of minor children or special needs dependents
  • Individuals concerned about beneficiaries’ financial discipline, divorces, or creditors
  • Anyone with a large IRA or Roth IRA wanting to preserve tax deferral for the next generation


Three Key Actions to Take Now


  1. Review Your Trust Documents
  2. Check IRA Beneficiary Designations
  3. Are your IRAs still naming a trust as a beneficiary?
  4. Would individual designations now make more sense?
  5. Coordinate with Your Advisory Team
  6. Your estate attorney, financial advisor, and tax professional should work together.
  7. The goal: protect your legacy while minimizing tax burdens for your heirs.

 

Why This Matters


This isn’t just about compliance — it’s about preserving your wealth and intentions across generations.


  • Stretch IRAs are still possible, but only with intentional trust design.
  • Subtrust planning gives you greater control, tax deferral, and peace of mind.
  • Taking action now may help avoid unnecessary tax erosion later.

 

Let’s Talk


If you’ve named a trust as your IRA beneficiary — or just want to make sure your estate plan still reflects your goals — now is the time to act.

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