Teddy

You know only a designated beneficiary can be an individual and then be able to use their individual life expectancy for RMD calculations and the Trust while clearly a deemed beneficiary cannot be a designated beneficiary. Even if paid to the kids the regulations prohibit the establishment of separate accounts for this definition you referenced. Norton review1.401(a)(9)-4, Q&A-5(c). Hope this helps Norton

B21, The issue is who is the deemed beneficiary and who is the designated beneficiary. For only the designated beneficiary can establish an Inherited IRA for life expectancy payments. As CJ Allen mentioned the IRS has in the past allowed for some of those that have specifically applied for a private letter ruling when a trust was the named beneficiary (deemed beneficiary) of an IRA to allow the trust beneficiaries of the trust to become the designated beneficiaries of the IRA. The only private letter rulings I have seen that allow for the beneficiaries of the estate (deemed beneficiary) to be treated as if they were the designated beneficiary of the IRA is when the beneficiary of the estate is the spouse and the spouse has complete control of the estate. I am not aware of any precedence that as CJ stated that allows for a non-person of an estate to be a designated beneficiary of the IRA. Your client should rely on the advice of their counsel to determine if filing for a private letter ruling to confirm whether the IRS would allow for this request of your client.