Section Newsletters

Articles From Francesca M. DeBella, J.D.

New IRS Private Letter Ruling Provides Guidance on Applying Internal Revenue Code Section 408 to Estate Beneficiaries of Retirement Accounts By Sandra D. Mertens & Francesca M. DeBella, J.D. Federal Taxation, October 2026 Section 408 of the Internal Revenue Code governs IRAs, including their tax treatment and distributions. Importantly, a direct trustee-to-trustee transfer is not treated as a distribution or rollover for these purposes. But what happens when an IRA owner dies without naming a beneficiary and the estate becomes the beneficiary? Private Letter Ruling 202631001 (July 31, 2026) has addressed this issue.

Spot an error in your article? Contact Celeste Niemann at cniemann@isba.org. For information on obtaining a copy of an article, visit the ISBA Newsletters page.

Select a Different Author