A retirement plan trust can play a key role in preserving retirement assets and directing distributions to beneficiaries in a way that aligns with your wishes and tax goals. For residents of Boron and surrounding Kern County communities, this guide explains how a retirement plan trust can be used alongside other estate planning tools like wills, advance health care directives, and powers of attorney. The Law Offices of Robert P. Bergman assists clients with practical planning that reflects family dynamics, retirement account rules, and current California law. This introduction outlines what you should consider when protecting retirement accounts and coordinating them with trust documents to achieve orderly succession and financial clarity.
Many people assume retirement accounts automatically pass to named beneficiaries without additional planning, but without the right structure those assets may be taxed, misdirected, or mismanaged after transfer. A retirement plan trust can provide tailored distribution direction, protect vulnerable beneficiaries, and help integrate account transfers with a broader estate plan that may include revocable living trusts, pour-over wills, and tax-aware strategies. Our approach explains options in clear terms, weighing the potential benefits and tradeoffs for individuals, couples, and families. If you own retirement accounts and want to preserve retirement income for heirs while minimizing administrative complexity, planning sooner rather than later is beneficial.
A retirement plan trust provides a structured way to receive retirement account proceeds while offering control over how distributions are handled for beneficiaries. It can address concerns such as preserving assets for minors, protecting funds from creditors, providing for a beneficiary with special needs, and coordinating distributions to minimize tax consequences. By naming a trust as the account beneficiary, you can protect assets from immediate spending, extend payout periods when appropriate, and align retirement account transfers with other estate documents to ensure consistency. This tool is particularly relevant where beneficiaries may not be prepared to manage large lump-sum inheritances or where additional safeguards and direction are desired.
The Law Offices of Robert P. Bergman provides practical estate planning services to residents throughout California, with an emphasis on thoughtful retirement account planning and trust administration. Our practice helps clients create revocable living trusts, pour-over wills, advance health care directives, and retirement plan trusts that work together to reflect each client’s priorities. We focus on clear communication, thorough document drafting, and careful coordination of beneficiary designations and trust terms. Clients in Boron, Kern County, and beyond receive guidance shaped by years of drafting and implementing estate plans and related filings, including Heggstad and trust modification petitions when needed to preserve client intent.
A retirement plan trust is a legal arrangement written to receive retirement account assets and to manage distributions to beneficiaries according to defined terms. It functions by naming the trust as beneficiary of retirement accounts such as IRAs or employer plans and then providing instructions within the trust for how those funds are to be paid out. The trust must be carefully drafted to comply with plan rules and tax regulations, and it must be kept coordinated with account beneficiary designations. Properly constructed, the trust can control timing, provide spendthrift protection, and specify tax-aware distribution methods that reflect the account owner’s overall estate plan and personal goals.
When creating a retirement plan trust, attention to technical details matters. The language must allow the trust to qualify for required minimum distribution rules when applicable, and trustees must follow procedures set by plan administrators. Considerations include whether to use a conduit trust that mandates distributions flow directly to beneficiaries or an accumulation trust that permits funds to remain in trust for longer periods. Each choice carries consequences for taxes, control, and beneficiary access. Our role is to explain the implications, draft documents that reflect your choices, and assist with beneficiary designation updates to ensure the trust performs as intended.
In straightforward terms, a retirement plan trust is a trust created to receive retirement account proceeds and direct how those proceeds are used over time. Unlike naming an individual as beneficiary, directing assets to a trust allows the account owner to specify distribution timing, protect funds from misuse, and impose conditions or protections for beneficiaries. The trust document sits alongside other estate planning instruments and must be carefully drafted to meet plan and tax rules. Its purpose is not only to transfer money but to preserve retirement assets for intended uses such as ongoing support, education, or long-term care needs while reducing the risk of unintended consequences.
Key elements of a retirement plan trust include clear trustee powers, beneficiary descriptions, distribution provisions, and language addressing tax treatment. The process typically begins with an inventory of retirement accounts and beneficiary designations, followed by drafting trust provisions that align with the account owner’s objectives. After signing, the account owner updates beneficiary designations to name the trust, and trustees are briefed on responsibilities. It is important to periodically review and update the arrangement as family circumstances, tax laws, or account balances change. Proper coordination reduces administrative friction and helps ensure distributions follow the intended path.
Understanding the terminology used in retirement plan trust discussions helps you make informed choices. Terms such as beneficiary designation, trustee, conduit trust, accumulation trust, required minimum distribution, and pour-over will appear frequently. Knowing what each term means will clarify how different approaches affect taxes, timing, and control over funds. A glossary of common terms can demystify the process and assist in conversations about drafting and funding the trust. This section provides clear definitions and practical implications of those terms so you can evaluate options with confidence and align your retirement account planning with broader estate goals.
A retirement plan trust is a trust specifically drafted to receive proceeds from retirement accounts and to direct the use and distribution of those proceeds for designated beneficiaries. The trust document includes provisions that address payout timing, tax considerations, trustee powers, and protection measures. When named as the beneficiary of an IRA or other qualified account, the trust becomes the legal recipient of the funds and then follows the trust’s distribution rules. Drafting must take into account plan documents and tax rules so that required minimum distributions and other regulations are handled correctly while meeting the account owner’s goals.
A conduit trust requires that retirement account distributions be passed through to beneficiaries immediately upon receipt by the trust, which can help preserve certain tax benefits but limits the trustee’s ability to retain funds within the trust. An accumulation trust allows the trustee to retain distributions and manage them within the trust for longer-term protection or oversight, but that approach can alter the tax treatment and available distribution periods. Choosing between these structures depends on priorities such as tax planning, creditor protection, beneficiary maturity, and the desire for ongoing management of funds.
A beneficiary designation is the instruction you provide to a retirement plan or account administrator naming who will receive the account assets upon your death. This designation typically overrides provisions in a will, which is why coordination with estate planning documents is essential. When naming a trust as beneficiary, the designation must match the trust language exactly so the account administrator can pay the trust directly. Regular review of beneficiary designations is important after life events such as marriage, divorce, births, or deaths to ensure the intended recipients receive the assets consistent with your estate plan.
A required minimum distribution, or RMD, is a tax rule that requires owners and certain beneficiaries of retirement accounts to take minimum withdrawals based on age and account balance. When a trust is involved, the trust’s terms and beneficiary status can affect how RMD rules apply and how payouts are calculated. Properly drafted trust provisions can allow beneficiaries to use available stretch or payout options under current laws, while inadequate drafting can unintentionally accelerate tax consequences. Awareness of RMD rules is a key part of integrating retirement accounts into an overall estate plan to reduce unnecessary tax burdens.
When deciding whether to name an individual beneficiary or a retirement plan trust, consider the tradeoffs between simplicity and control. Naming an individual is administratively straightforward but provides little protection from creditor claims, beneficiary mismanagement, or unintended consequences after remarriage. A trust adds procedural steps and technical requirements but offers structured distribution, protective conditions, and the ability to coordinate with other estate documents. The choice depends on family circumstances, tax considerations, beneficiary capabilities, and the desire for ongoing oversight. A careful comparison helps determine the path that best preserves assets for intended uses.
A limited approach can be suitable when retirement accounts are modest in size and you have clear, capable beneficiaries who do not require additional protection or guidance. If beneficiaries are adults who are financially responsible and there are no concerns about creditor claims, special needs, or blended family complexities, naming individuals directly can reduce paperwork and administrative hurdles. In such situations, combining a beneficiary designation with a will and power of attorney may achieve the client’s goals without the need for trust formation. Periodic reviews remain important to ensure designations reflect current intentions and life changes.
A limited approach can also be appropriate when family relationships are uncomplicated and beneficiaries possess the maturity and financial knowledge to manage lump-sum distributions. If the primary priority is to transfer assets quickly and without the costs of trust administration, naming beneficiaries directly may be the most efficient route. However, even in these cases, it is prudent to document clear intentions through wills and beneficiary designations and to review retirement plan rules periodically. Regular check-ins help prevent unintended outcomes and ensure that the chosen method continues to match personal circumstances and state law developments.
Comprehensive planning is often needed when family structures are complex, such as blended families, minor or dependent beneficiaries, or when tax minimization is a key goal. In these scenarios, multiple legal documents must work together so that beneficiary designations, trust terms, wills, and powers of attorney produce consistent results. Coordinated planning allows for tailored distribution timing, addresses potential conflicts between documents, and provides a roadmap for trustees and family members. Taking a holistic view helps reduce the risk of unintended disinheritance, tax surprises, or administrative challenges during a stressful time for loved ones.
Another reason to pursue comprehensive service is to align retirement accounts with trust provisions so distributions occur according to a unified plan. Coordination ensures that a revocable living trust, pour-over will, and retirement plan trust do not conflict, that beneficiary designations are updated after trust modifications, and that trustees understand how to manage and distribute funds. This alignment supports long-term goals such as asset protection, care for vulnerable beneficiaries, charitable giving, or intergenerational planning. Proper coordination reduces confusion for family and fiduciaries and supports smoother administration after an account owner’s death.
A comprehensive approach brings clarity and consistency to how retirement assets are handled at the end of life. It helps ensure that beneficiary designations and trust provisions work together to achieve the owner’s intentions while potentially minimizing tax exposure and administrative delays. This approach also permits proactive planning for scenarios such as incapacity, remarriage, or beneficiary needs, creating provisions that protect assets and guide trustees. By addressing multiple documents and potential contingencies, a comprehensive plan reduces the risk of disputes and eases the burden on family members tasked with implementing the estate plan.
Beyond legal coordination, a thorough plan can improve financial outcomes by directing distributions in ways that consider tax timing and future income needs. Trustees and beneficiaries benefit from clear instructions about allowable uses, distribution timelines, and trustee authority. For families with unique needs, such as beneficiaries who receive government benefits or who require long-term oversight, a comprehensive trust framework can preserve eligibility while providing necessary support. Regular reviews of the plan ensure it remains effective as laws and personal circumstances evolve.
An advantage of a coordinated retirement plan trust is the ability to plan distributions to be mindful of tax consequences and lifetime income objectives. Thoughtfully drafted documents can create payout patterns that reduce the immediate tax impact on beneficiaries, allow for orderly transfers over multiple years, and preserve retirement income streams for surviving spouses or dependents. Trustees can be instructed to consider tax implications when executing distributions, and the overall estate plan can incorporate retirement accounts in a way that balances liquidity needs with tax-efficient succession strategies, which may lead to better after-tax results for heirs.
A comprehensive approach provides clear direction to trustees and beneficiaries, reducing ambiguity and the potential for family disputes. Trust provisions can include protections against creditors, safeguards for beneficiaries who are minors, and instructions for managing funds over time. These measures help preserve the intended purpose of retirement assets whether for education, ongoing support, or long-term care. Additionally, the clarity afforded by coordinated planning offers peace of mind to account owners who want their financial legacy handled according to their values and intentions without placing undue administrative burdens on loved ones.
Regular review of beneficiary designations is essential because designations made directly on retirement accounts typically override provisions in wills. Life events such as marriage, divorce, births, or deaths can necessitate updates to ensure designations match current intentions. When a trust is named as beneficiary, confirm that the account holder’s trustee and trust name are accurate and that the trust language remains consistent with account rules. Scheduling periodic reviews of both account paperwork and trust documents helps prevent unexpected outcomes and maintains coherence across all estate planning instruments.
Choosing the right trustee and providing clear guidance in the trust document are important steps to ensure proper management and distribution of retirement funds. Trustees should understand responsibilities such as tax reporting, timing of distributions, and communication with account administrators. When the trust contains complex provisions, include instructions that help trustees make consistent decisions that reflect the account owner’s priorities. Consider naming successor trustees and providing rules for conflicts of interest, investment approach, and distribution discretion so trustees can act confidently and in accordance with the plan owner’s intent.
Consider a retirement plan trust if you have beneficiaries who may need protection from creditors, divorce, or poor financial decisions, or if you wish to control income timing after your death. Individuals who want to coordinate retirement accounts with a revocable living trust, ensure care for a dependent, or preserve benefits for a surviving spouse often find this tool beneficial. It is also worth considering when tax planning is important and when you prefer structured payouts rather than lump-sum distributions. Evaluating family dynamics and tax consequences helps determine whether a trust aligns with your overall legacy objectives.
You might also consider adding a retirement plan trust if you expect to modify other estate documents in the future, intend to leave assets to a charitable remainder, or wish to keep certain transfers out of public probate records. The trust can be crafted to work with Pour-Over Wills, certification of trust documents, and other instruments to simplify administration. Even for modest estates, a trust can provide peace of mind by specifying how retirement funds should be used for education, health care, or long-term support, while reducing uncertainty for your beneficiaries and loved ones.
Common situations include having minor beneficiaries, leaving assets to a beneficiary with special needs, protecting inheritance from creditors or divorce, or wanting to stagger distributions over time. People with blended families often use trusts to ensure a surviving spouse receives necessary income while preserving assets for children from a prior marriage. Business owners and those with significant retirement savings may prioritize tax-aware distribution strategies. In each case, the trust offers a framework to document intentions clearly and provide trustees with instructions that reflect the account owner’s financial, medical, and family priorities.
When beneficiaries are minors or young adults, a retirement plan trust can hold funds until beneficiaries reach specified ages or milestones so that assets are used for education, health, and maintenance rather than a premature lump-sum distribution. The trust can designate how distributions are to be made for specific purposes and include protections against wasteful spending. Appointing a responsible trustee and including instructions for stewardship helps ensure the funds support long-term wellbeing and development of younger beneficiaries rather than being quickly depleted.
If a beneficiary has disabilities or receives means-tested government benefits, a retirement plan trust can be drafted to preserve eligibility for public assistance while providing supplemental support. Trust terms can limit use of principal to approved purposes and assign oversight duties to a trustee who understands the beneficiary’s needs. This approach allows account owners to provide meaningful, long-term care without jeopardizing essential benefits. Trust language can be tailored to address medical needs, housing, education, or therapeutic services while protecting the beneficiary’s long-term interests.
Blended families frequently benefit from retirement plan trusts that balance the needs of a surviving spouse and children from prior relationships. A trust can allocate income to a spouse while protecting principal for children, or it can stagger distributions to meet different family priorities. Clear instructions reduce the chance of conflicts after an account owner’s death and provide a neutral framework for managing competing goals. By articulating how assets should be used and who receives what and when, a trust supports fairness and long-term family stability while reflecting the account owner’s intentions.
The Law Offices of Robert P. Bergman serves clients in Boron and Kern County with focused estate planning services including retirement plan trusts, revocable living trusts, wills, advance health care directives, and financial powers of attorney. We help clients evaluate retirement accounts and determine whether naming a trust as beneficiary fits their overall plan. Our role includes drafting documents, coordinating beneficiary designations, and guiding trustees through administration tasks. With practical recommendations and clear explanations, we support clients in preparing plans that reflect personal values while addressing the legal and tax considerations that affect retirement assets.
Clients work with our firm because we focus on delivering clear, implementable estate plans that address retirement accounts and related issues. We prioritize thorough document drafting that aligns beneficiary designations with trust language and consider the tax and administrative consequences of different trust structures. Our process includes careful review of account types, discussion of trustee roles, and regular plan updates to reflect life changes. This practical orientation helps clients make informed decisions and ensures that documents function as intended when trustee action or beneficiary claims arise.
We also emphasize communication and accessibility for clients throughout Kern County, including Boron residents who require guidance on retirement planning and estate settlement. Our team explains alternatives in plain language, outlines pros and cons, and prepares documents that are intended to be durable while allowing for future adjustments. Whether your goals include protecting a surviving spouse, preserving assets for children, or planning for a dependent with special needs, our approach provides a coherent path from initial planning through funding and administration.
Finally, our firm assists with related petitions and filings that sometimes arise in administering trusts, such as Heggstad petitions, trust modification petitions, and certification of trust matters. We coordinate with financial institutions and plan administrators to implement beneficiary changes and advise trustees on compliance with distribution rules. By handling both the planning and the follow-through, we help reduce the administrative burden on families and promote a smoother transition aligned with the account owner’s long-term objectives.
Our process begins with a comprehensive review of your retirement accounts, current beneficiary designations, family situation, and long-term goals. We then recommend an approach that may include drafting a retirement plan trust, updating a revocable living trust, and creating supporting documents like a pour-over will and advance health care directive. After drafting, we help with signing and guide you through updating beneficiary designations to ensure the trust is funded correctly. The goal is to provide clear documentation and practical steps so trustees and beneficiaries can follow your wishes with confidence.
The first phase focuses on gathering information about retirement accounts, current beneficiaries, and family dynamics. During an initial consultation, we document account types, plan administrators, and any existing estate planning documents such as revocable living trusts or wills. This baseline allows us to evaluate whether naming a trust is appropriate and to identify any conflicts or necessary updates. We discuss distribution objectives, tax considerations, and potential trustee candidates. This step establishes the facts needed to propose a tailored trust structure and a clear plan for implementing beneficiary designation changes.
Assessing personal goals and family needs helps shape the trust structure. We discuss who you want to benefit from retirement assets, whether you have dependents or beneficiaries with special needs, and how you want funds managed and distributed. This conversation identifies priorities such as protecting funds from creditors, coordinating with other estate documents, or providing ongoing income. Understanding these factors informs the choice between conduit and accumulation provisions and clarifies trustee responsibilities, ensuring the trust language reflects your objectives and provides guidance for future administration.
A document and beneficiary review compares your current beneficiary designations against drafted trust provisions to identify mismatches or gaps. We verify that nominee names, account numbers, and trust titles match plan administrator requirements and ensure there are no unintended beneficiaries named. If discrepancies exist, we outline steps to correct them and prepare the necessary trust amendments or beneficiary designation forms. This review reduces the risk of account administrators paying funds contrary to your intentions and helps streamline administration when the time comes to transfer assets.
Once the preferred structure is chosen, we draft the retirement plan trust and related documents, ensuring language addresses payout timing, trustee duties, and tax considerations. The drafting phase includes creating a revocable living trust or pour-over will if needed, and incorporating provisions for successor trustees, trustee compensation, and dispute resolution. After preparing drafts, we review them with you and make revisions to reflect your final decisions. Execution is handled with clear instructions to sign and notarize documents as necessary and to update account beneficiary designations with plan administrators.
Drafting trust terms involves specifying how and when retirement funds should be distributed, granting trustees the powers necessary to carry out duties, and including provisions to address tax reporting. The document should allow trustees to access account statements, engage tax professionals, and make distributions consistent with both trust language and plan rules. Well-drafted trustee powers reduce ambiguity, enable prudent investment and distribution decisions, and provide a framework for handling special circumstances such as beneficiary incapacity or disputes. Clear drafting helps trustees administer the trust efficiently and in line with your intentions.
After execution, coordinating with account administrators is essential to ensure the trust becomes the official beneficiary. We assist by preparing beneficiary designation forms, providing certification of trust documents when requested, and communicating with plan administrators to confirm acceptance. This phase includes verifying that the trust language meets the administrator’s requirements and that the account records reflect the updated beneficiary. Proper coordination reduces the risk of administrative delays and helps ensure a smooth transfer of retirement assets when the time comes.
The final phase is ongoing maintenance, which includes periodic reviews to account for changes in family circumstances, tax law, or account balances. Funding steps may require additional beneficiary updates as new accounts are opened or assets transferred. We provide trustee support to help with distribution decisions, tax reporting, and interaction with financial institutions. Regular check-ins and planned updates keep the trust effective and aligned with your goals. Ongoing attention ensures the plan remains current and that trustees are prepared to implement your wishes in an organized manner.
Periodic reviews assess whether the trust and beneficiary designations continue to reflect your wishes in light of life changes such as births, deaths, divorces, or relocations. During review sessions, we recommend amendments when necessary and advise on modifications to address tax law updates or changes in financial circumstances. Amendments should be carried out with proper formalities to preserve the integrity of the trust and ensure that account administrators and trustees can rely on current documents. Regular maintenance preserves the effectiveness of the estate plan over time.
Trustee assistance extends to helping trustees understand their responsibilities, prepare necessary tax filings, and coordinate distributions consistent with trust terms. Trustees may need guidance for reporting retirement account proceeds, calculating required minimum distributions for beneficiaries, and handling communications with beneficiaries and financial institutions. We offer practical support and documentation to reduce administrative errors and to ensure fiduciary duties are met. This assistance helps trustees act confidently and in a manner that honors the account owner’s intent while meeting legal and tax obligations.
A retirement plan trust is a trust drafted to receive proceeds from retirement accounts and to control how those proceeds are distributed to beneficiaries. It is appropriate when you want to impose conditions on distributions, protect funds from creditors or divorce, provide for minor beneficiaries, or coordinate retirement assets with a broader estate plan. The trust must be carefully worded to work with plan rules and tax regulations, and it should be named properly as beneficiary. Considering a trust makes sense when beneficiaries might benefit from oversight or when you want to control timing and purpose of distributions to align with your goals and family circumstances.
Naming a trust as beneficiary can affect tax treatment depending on the trust structure and beneficiary status. When trusts are structured to allow beneficiaries to stretch distributions in line with life expectancy rules, tax outcomes can be more favorable. Conversely, trust language that retains funds within the trust can accelerate taxable distributions or limit payout options, potentially increasing immediate tax liabilities. Careful drafting helps preserve tax benefits where possible and ensures trustees and beneficiaries understand tax reporting responsibilities. Evaluating tax effects in advance allows for planning that balances control with efficient tax outcomes for heirs.
A conduit trust directs retirement account distributions received by the trust to be paid immediately to the named beneficiary, preserving some payout options available under plan rules. An accumulation trust allows the trustee to retain distributions within the trust and manage funds on behalf of beneficiaries, which can provide protection but may alter tax treatment and timing. Each structure has distinct implications for flexibility, creditor protection, and tax consequences. Selecting the appropriate form depends on factors such as beneficiary maturity, need for protection, and the owner’s objectives for controlling distribution timing and usage.
Naming a trust as beneficiary can introduce additional administrative steps, as plan administrators may require certification of trust documents before releasing funds. While this can add some processing time, proper preparation helps minimize delays. Ensuring that the trust is properly executed, that the designation form matches trust titles, and that a certification of trust is available for financial institutions reduces potential hold-ups. Clear communication with account administrators and having trust documentation on file can streamline the transfer process and speed distributions to intended recipients.
To ensure beneficiary designations match your trust, review account records and compare the exact name of the trust against the designation forms. Minor discrepancies in naming can cause payment to the wrong recipient or trigger administrative delays. Provide the plan administrator with a certification of trust and confirm the acceptance of the trust as beneficiary. Regular reviews after life events or document amendments help keep designations aligned, and consulting with counsel during updates reduces the chance of unintended outcomes and helps maintain consistency across all estate planning instruments.
A retirement plan trust can be drafted to preserve eligibility for certain government benefits while providing supplemental support to a dependent. Special trust provisions can limit distributions for specific purposes and avoid direct transfers that might disqualify benefits. Careful drafting creates a vehicle that supplies necessary resources without displacing means-tested aid. Because benefit rules are technical and can change, it is important to tailor trust language with an eye toward preserving eligibility and to coordinate with social services or benefits advisors to ensure the approach meets both legal and practical needs of the beneficiary.
Selecting a trustee involves balancing trustworthiness, financial judgment, and availability to carry out fiduciary duties. Many choose a family member, a trusted friend, or a professional fiduciary depending on the complexity of the trust and the needs of beneficiaries. It is beneficial to name successor trustees in case a trustee becomes unable to serve. Trustees must be prepared to handle tax reporting, distributions, and communications with financial institutions. Discussing expectations with prospective trustees and providing clear trust instructions helps ensure that the trustee can perform responsibilities effectively when the time comes.
Yes, you should update plan documents after major life events such as marriage, divorce, births, or deaths to make sure beneficiary designations and trust provisions remain aligned with your current intentions. Changes in tax law, account types, or financial objectives may also warrant revisions. Periodic reviews help identify inconsistencies between account beneficiary forms and trust language and allow for necessary amendments. Maintaining updated documents reduces the risk of unintended distributions and ensures that your estate plan continues to reflect your priorities and family circumstances over time.
Required minimum distributions affect planning because they establish minimum payout obligations based on age and account balances that can influence tax timing for beneficiaries. When a trust is the beneficiary, the trust’s terms can determine whether beneficiaries can use life expectancy payout options or whether distributions are accelerated. Properly drafted trusts can preserve available payout methods and coordinate with RMD rules to optimize tax outcomes. Trustees should work with tax professionals to calculate RMDs and make timely distributions in accordance with both trust provisions and current federal rules to avoid penalties.
A retirement plan trust can be modified in certain circumstances, depending on whether it is revocable or irrevocable and on the formalities used to create it. Revocable trusts generally allow changes by the account owner during their lifetime, while irrevocable trusts are more limited. If changes are needed after funding, options may include amending a revocable trust, coordinating beneficiary redesignations, or, when appropriate, seeking court approval for modifications through trust modification petitions. Consulting counsel helps determine the available options and the proper process to preserve the legal and tax integrity of the arrangement.
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