"The return guidance incorrectly describes the 10-year rule as requiring annual distributions in each year following the participant's death even though the 5-year rule has no such requirement. Furthermore, when the participant dies after attaining the participant's required beginning date, the IRS guidance prevents a disfavored individual beneficiary from continuing to use the participant's life expectancy to determine annual minimum required distributions.... These limitations are not consistent with the stated purpose of the SECURE Act MRD provisions, the long-standing IRS regulations interpreting the MRD rules, or the amended MRD statute as a whole."