Sandra Nguyen spent thirty-one years as a senior systems engineer at Raytheon Intelligence & Space in McKinney. She was not, by any reasonable measure, a person who left important things unexamined. She had read every line of every benefits enrollment form. She had reviewed her company pension documentation annually. She had three-ring binders organized by year going back to 1994.
When her husband Gary died in 2021 — a heart attack, sudden, at sixty-four — Sandra did what careful people do. She hired an estate planning attorney in Frisco. She rolled Gary's 401(k) into her existing Fidelity IRA, bringing the balance to $2.3 million. She had a revocable living trust drafted. She updated every beneficiary designation, financial account, and insurance policy. She named her three adult children — Tyler, Melissa, and Cooper — as equal beneficiaries of the trust. And on the Fidelity beneficiary designation form for her IRA, she wrote what seemed, at the time, like the obvious answer:
The Sandra Nguyen Revocable Trust, dated November 14, 2021.
Her reasoning was clear. Her trust controlled everything. It said exactly who got what, in what order, under what conditions. Naming the trust as IRA beneficiary would "unify the estate plan." Everything would flow through one document. Her attorney reviewed the form and said nothing.
Sandra died in February 2026, at sixty-two, from a sudden cardiac event. Her trust became irrevocable. Her IRA — all $2.3 million — passed to the trust as she had instructed.
Over the next ten years, that single line on a beneficiary designation form cost her three children more than $300,000 in federal income taxes they were not legally required to pay.
Why IRAs Don't Work Like Everything Else in Your Estate
Under Texas law, beneficiary designations control non-probate transfers. Under Tex. Est. Code § 111.052, the person named on an IRA, 401(k), or life insurance policy receives those assets regardless of what the will or trust says. That principle is widely understood. What is far less understood is what happens when the trust itself is the named beneficiary.
Retirement accounts — IRAs, 401(k)s, 403(b)s — exist inside a separate legal universe governed by the Internal Revenue Code and Treasury regulations. The rules about who gets the money, how fast they must take it, and how it is taxed along the way are determined not by your estate plan but by the IRS. And those rules treat trusts very differently from individuals.
When you name a person directly on your IRA, they become what the IRS calls a designated beneficiary. Under the SECURE Act of 2020, most adult children who inherit an IRA are "non-eligible designated beneficiaries" — they must take all distributions within ten years of your death, but they can pace those withdrawals however they like within that window. Critically, they are taxed at their own individual income tax rates, which for most adult working professionals run between 22 and 32 percent.
When you name a trust as your IRA beneficiary, those rules change — and the stakes get significantly higher.
The See-Through Test: Four Requirements, One Expensive Failure
The IRS allows a trust to function as an IRA beneficiary under specific conditions. Under Treasury Reg. § 1.401(a)(9)-4, a trust can "look through" to its individual beneficiaries — preserving the ten-year distribution window — if it meets four requirements:
- The trust is valid under state law (a Texas revocable trust becomes irrevocable at death and qualifies)
- The trust is irrevocable at the time of the IRA owner's death
- All trust beneficiaries who could receive IRA distributions are identifiable individuals — no charities, no unidentified class of beneficiaries, no "estate of the deceased"
- A copy of the trust instrument (or a list of all trust beneficiaries) is provided to the IRA custodian by October 31 of the year following the year of death
Sandra's trust met all four requirements. Tyler, Melissa, and Cooper were clearly identified. There were no charities. The trust was irrevocable at her death. It qualified as a see-through trust.
So what went wrong?
Conduit vs. Accumulation: The Distinction Nobody Explains
A qualifying see-through trust comes in two varieties, and the difference between them cost Sandra's children $300,000.
A conduit trust requires the trustee to pass through all IRA distributions to the individual beneficiaries immediately. The money does not stay inside the trust. It flows directly to Tyler, Melissa, and Cooper. As a result, they are taxed on those distributions at their own individual income tax rates. The ten-year rule applies to each of them personally.
An accumulation trust — which Sandra's was — gives the trustee discretion. Tyler, as successor trustee, could decide how much to distribute each year and could keep money inside the trust rather than distributing it immediately. That discretion was intentional. It protected the inheritance from creditors, allowed for thoughtful management, and gave the trust flexibility Sandra wanted.
But accumulation trusts pay income taxes at trust rates — and trust income tax rates are unlike anything most families encounter.
In 2026, a trust hits the 37 percent federal income tax bracket at just $15,650 of taxable income. For comparison, a single filer doesn't reach 37 percent until their income exceeds approximately $609,000.
Here is what that means for Sandra's family: her $2.3 million IRA must be fully distributed within ten years of her death. Tyler, as trustee, withdrew roughly $230,000 per year. Once the trust's taxable income crossed $15,650, every additional dollar of IRA distribution was taxed at 37 percent. The trust paid approximately $80,000 in federal income taxes per year on those withdrawals.
If Tyler, Melissa, and Cooper had been named directly on the Fidelity form instead of the trust, each sibling would have received approximately $76,700 per year. At their income levels — Melissa teaches in Plano, Cooper was finishing graduate school — their marginal federal rates on those withdrawals would have been 22 to 24 percent. Combined, they would have paid roughly $50,000 per year in federal income taxes on the same $230,000 in distributions.
Over ten years: the trust approach cost the family roughly $300,000 in extra federal income taxes. Not because of anything that went wrong. Because of one line on a beneficiary designation form that seemed, on the day it was signed, like responsible housekeeping.
What Happens When the Trust Doesn't Even Qualify
Some trusts don't meet the four IRS requirements for see-through treatment — most commonly because a charity has a remainder interest, or because a class of unidentified beneficiaries could theoretically receive distributions. In those cases, the IRS treats the IRA as having no designated beneficiary at all. The consequences are worse than the accumulation trust scenario above.
Questions about estate planning? A WG Law attorney can walk you through your options.
If the IRA owner died before their Required Beginning Date (age 73 under current law), the entire IRA must be distributed by December 31 of the fifth year after death — not the tenth. Five years of forced withdrawals, at trust income tax rates, from a $2 million account. The tax arithmetic is punishing.
When Naming a Trust as IRA Beneficiary Is the Right Move
There are situations where a trust as IRA beneficiary is exactly the right answer. Families who need trust control over IRA distributions — not just the tax outcome — should understand when the tradeoffs are worth it.
Minor children. A minor child cannot directly inherit an IRA. If a parent names a minor as IRA beneficiary, the court appoints a guardian of the estate to manage those funds under judicial supervision until the child turns 18. A properly structured IRA trust can hold and manage those distributions for the child until a more appropriate age — 25, 30, or whenever the parent's plan specifies. For more on what happens when minor children inherit money in Texas, the legal gap is significant and often overlooked.
Special needs beneficiaries. A beneficiary who receives SSI or Medicaid cannot inherit retirement funds directly without risk of losing those government benefits. A carefully drafted special needs trust coordinated with IRA distribution rules can preserve both the inheritance and government benefit eligibility. This requires precise drafting — the trust must meet IRS see-through requirements while also satisfying the Medicaid and SSI asset rules.
Blended families. In a blended family where a decedent wants to provide income to a surviving second spouse while ultimately preserving the principal for children from a first marriage, a qualifying trust can accomplish both goals. The structure requires careful planning with someone who understands both the IRS distribution rules and the Texas community property rules that govern how the IRA was originally funded.
Spendthrift protection. If a beneficiary has serious creditor problems — active litigation, business liability, or a history of financial instability — the protection of keeping IRA proceeds inside a spendthrift trust may outweigh the compressed tax rates. This is a genuine tradeoff that depends on the beneficiary's specific circumstances and the size of the estate.
The Smarter Approach: Coordinate, Don't Override
The most common misconception is that naming individuals directly on an IRA somehow removes them from the estate plan. It doesn't. The estate plan and the IRA beneficiary designation can work together — they simply have to be coordinated rather than merged.
For most Texas families, the better structure looks like this:
- Name individuals directly on the IRA. Each beneficiary receives their share, takes distributions at their own income tax rate under the ten-year rule, and maintains maximum flexibility. There is no trust rate penalty. The IRS rules work as intended.
- Fund the trust with non-retirement assets. The home, the brokerage account, the vacation property, the taxable investment accounts — these assets pass through the trust's instructions, receive the protections the trust was designed to provide, and are not subject to the IRS retirement account rules. They may also receive a step-up in cost basis at death, making the tax treatment even more favorable.
- Use Roth conversions strategically. A Roth IRA has no required minimum distributions during the owner's lifetime, and distributions from inherited Roth IRAs are income-tax-free. Converting a traditional IRA to Roth over time — paying taxes now at potentially lower rates — can fund the trust with assets that won't generate taxable trust income on the back end. This is a legitimate strategy for families with the liquidity to pay conversion taxes during their lifetime.
The goal is not to keep everything in one document. The goal is to make sure every asset reaches its intended beneficiary at the lowest possible tax cost.
What Sandra Should Have Done
Sandra's estate plan was well-designed for her non-IRA assets. The trust instructions were clear. The trustee discretion was appropriate. The spendthrift protections made sense. Her mistake was not the trust — it was the single decision to name the trust as the IRA's primary beneficiary when she could have named Tyler, Melissa, and Cooper directly.
A different beneficiary designation form — three lines of names instead of one trust name — would have preserved everything the trust was meant to accomplish for her other assets while reducing the income tax burden on her IRA by approximately $300,000 over ten years.
She could have made that change at any time during her lifetime. The Fidelity form takes fifteen minutes to update. No court approval is required. No trust amendment is needed. It is one of the most consequential — and most overlooked — actions in estate planning.
Talk to an Estate Planning Attorney Who Understands the Tax Side
The IRA beneficiary rules are among the most technically demanding areas of estate planning, sitting at the intersection of federal tax law, IRS regulations, state property law, and trust administration. Most estate planning attorneys handle the trust structure well. Fewer have the tax background to evaluate the IRA coordination question with the depth it deserves.
At WG Law, Carla Alston brings an LL.M. in Taxation from NYU School of Law — the most respected tax LL.M. in the country — and thirty-nine years of estate planning and tax practice, including years as an in-house tax attorney before opening her own firm. She works directly on tax-smart estate planning, IRA coordination, and the kind of beneficiary designation review that most families never think to request until it's too late.
If your IRA names a trust — or if you haven't reviewed your IRA beneficiary designations since setting up your estate plan — that review is worth scheduling before the next life change makes it an emergency.
WG Law serves clients in McKinney, Southlake, Frisco, Plano, Allen, and across the DFW metroplex from offices in McKinney and Southlake. Call 214-250-4407 or request a consultation to speak with our estate planning team.
For related reading, see our articles on the SECURE Act 10-year rule for inherited IRAs in Texas, why beneficiary designations control half your Texas estate, tax mistakes Texas CPAs miss in estate plans, and what Texas estate planning typically costs.
This article is provided for general informational purposes only and does not constitute legal or tax advice. IRA distribution rules, income tax rates, and trust taxation are governed by federal law and individual circumstances that vary by client. The figures and comparisons in this article use approximate values for illustrative purposes. The compressed trust income tax bracket thresholds referenced reflect 2026 IRS guidance and are adjusted annually for inflation. For guidance tailored to your situation, consult a licensed Texas estate planning attorney and a qualified tax professional.