The 10-year rule, applicable to most funds that will receive retirement benefits after passage of the Designation of Every Community Retirement Improvement Act (SAFE Act), presents a dilemma for non-Roth individual retirement accounts. For the vast majority of beneficiaries whose income level does not rise to the highest income tax bracket, leaving these assets in trust can double or triple their income tax due to income locking in the brackets of income tax of the highly compressed trust.