Folks,

Could use a little input, if possible. I’ll present in outline form.

1) Distant cousin passes in her late 50s in 2000. Leaves her IRA via beneficiary designation to her trust (Joan”s trust).
2) Joan’s trust names her brother as a primary beneficiary and 4 successor beneficiaries once her brother passes. I believe the trust qualifies as a see thru/conduit trust and this has been confirmed by attorneys. The RMDs flow from the original IRA to the brother’s own trust (he is special needs with all of his personal assets held in trust for his benefit until he passes).
3) Brother, I assume, had to use the single life expectancy factor to calculate RMDs. Life expectancy was something like 25.8 years at the time of his sister’s death. Denominator should have declined by 1 each year, correct?
4) Fast forward 20 years and brother dies. Trust states that all assets are to be distributed free and clear of the trust to 4 successor beneficiaries.
5) For the successor beneficiaries, do post-SECURE act rules for inherited IRAs (technically inherited-inherited IRA) apply such that the IRAs now only be emptied by the 10th year following the brother’s death? Or because of the scenario above, does one have to use another set of rules for emptying the IRAs?

I can provide additional info if needed, but hoping for some input from the experts!

Thanks in advance!

SR