Hello,

Note the following and my assumptions. Please provide your feedback/input where applicable in terms of whether my understanding of matters is correct and advisable.

Husband (65) and wife (64; to turn 65 in a few months), 2 children (35 and 33).
Husband passed away, leaving 100% of his IRA to his oldest child. Wife is the sole contingent beneficiary.
Oldest child will likely disclaim part of the IRA. Even though his RMD’s will be less than wife’s, assume wife requires some of the income from Deceased Husband’s IRA (and child would need to start RMD’s by 12/31/2013 and include this in his income). Due to the beneficiary designations, the disclaimed part should go to wife. Partial disclaimers are allowed as are full disclaimers. Do custodians vary in terms of the logistics involved in order to process a partial disclaimer? Or is this solely governed by IRS Code Section 2518?
Wife will name child 1 as the sole primary beneficiary of the Disclaimed IRA she receives.
Since wife and her deceased husband were around the same age, wife will not need to take RMD’s from the disclaimed IRA she receives until the year after turning 70 1/2 (in addition to RMD’s from her own IRA, of which each child is a 50/50 beneficiary).
Due to their ages, wife should treat the partially disclaimed IRA she is receiving as her own, rather than as a spousal beneficiary.
Oldest child will make sure the part of the IRA he is not disclaiming gets titled correctly as an Inherited IRA via a Trustee-to-Trustee transfer.
Wife will make sure the part of the IRA she is receiving (from oldest child’s disclaimer) gets titled correctly as her own IRA via a Trustee-to-Trustee transfer.
Letters will be sent to the custodian documenting everything being done as written proof of the transactions to ensure the partial disclaimer is done correctly and the newly created IRA’s (one inherited and one spousal) are established correctly.
Please advise if I should be aware of any specific items regarding the above based upon the fact pattern. Thank you.