"[U]nder the old rules, a trust with a mix of Eligible and Non-Eligible Designated Beneficiaries would have been automatically subject to the 10-Year Rule for Non-Eligible Designated Beneficiaries. Under the new rule, if the trust is divided into separate subtrusts for each beneficiary, the Eligible Designated Beneficiaries can each receive 'stretch' distributions over their own life expectancy -- while only the Non-Eligible Designated Beneficiaries will be subject to the 10-Year Rule. Notably, the IRS regulations only allow this 'separate accounting' treatment when the trust document includes a provision to divide the trust into separate subtrusts before the account owner's death."  MORE >>