Klaus Gottlieb, Esq.

Charitable planning · Retirement assets Municipal bonds change what the trust earns. They do not erase the ordinary income it received from the IRA. By Klaus Gottlieb, Esq. · October 6, 2026 · 11 min read Short answer. A properly designed charitable remainder trust can use inherited IRA proceeds to make payments to children over their lifetimes or a term of up to twenty years. But buying municipal bonds inside the CRT does not make those payments immediately tax-free. The IRA proceeds...

A Delaware statutory trust is not a donative trust of the sort estate planners usually mean by the word. Delaware law defines a statutory trust as an unincorporated association and, unless its governing documents provide otherwise, a separate legal entity. A syndicated DST used in a § 1031 exchange is then deliberately constrained so that federal income-tax law can look through that state-law entity. Under the facts of Rev. Rul. 2004-86, a single-class investment trust whose trustee lacks...

Short answer. A NICRUT and a NIMCRUT use the same net-income limitation: each year, the trust pays the lesser of the stated unitrust amount or its trust accounting income. The difference is that a NIMCRUT keeps track of prior shortfalls and may pay them later. But the makeup account is useful only if the trust will remain a NIMCRUT and can later produce enough trust accounting income to exceed the current year's regular unitrust amount. If the trust flips to a straight CRUT, any unpaid makeup...