@Drphibes  "pay the tax at the Trust level (probably way higher than at the beneficiary level, but hey)"

I always have to think that through, when as in this case most or all of the income is LTCG.  If the beneficiaries are in a lower bracket where they can absorb some tax-free and more at lower brackets, then IRS wins.  But in many cases, the beneficiaries pay on LTCG at the same rate as the trust, and the spike in income might disqualify them from other benefits or increase their Medicare premiums.  

This case, it sounds like some of the K-1s are being mailed to a trailer park, and the less money is distributed the less fentanyl might be crossing the border.