Currently the beneficiary of the Beneficiary IRA Trust is taking distributions as a spouse from her account.  She is up in years and the children will be the beneficiaries according to the Qtip Irrevocable trust after her death.  The original IRA owner passed on 2014.  Will the children be required to distribute out of their beneficiary accounts according the old five year rule OR will the beneficiary trust consider the date of death of the current recipient for a 10 year payout that is currently required?