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Had the individual been the sole beneficiary of the qualified plan or IRA, all distributions to her would have been taxed at ordinary rates.
However, distributions from a CRUT will be taxed to the individual beneficiary according to the type of income it represents, under special “tiering” rules applicable only to remainder trusts.
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Kathleen Stephenson
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Lisa B. Petkun
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Lisa B. Petkun is a partner in the tax department at Pepper Hamilton LLP.
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