Client age 83, married. Wife also 83 and incapacitated. She has a revocable trust. He has will with trust for wife if he dies first. We feel we do not want the wife to be the beneficiary of the husband’s IRA because of her incapacity (IRA Value $1.2 mil.). She has full time need for care. Total assets of H&W $6,000,000. Her trust has $2.5 mil. in it ($1.5 mil liquid the rest in beach property, not rented).

It appears we could name either trust the beneficiary (wife is primary in her trust and preferred beneficiary, discretionary, in H’s will). But, it also seems we could name husband’s estate the beneficiary, thereby stretching out the payments using the current payout schedule (his life expectancy, which seems to be the same as hers) but name the three children contingent beneficiaries. With named contingent beneficiaries, can the husband’s estate disclaim its (or some of its) interest in his IRA which named his estate the primary beneficiary and the three children inherit as the named contingent beneficiaries and be able to stretch according to their life expectancy as beneficiary IRA’s? Would this give a second look at the appropriate strategy at the death of the husband?

Which of these (or any additional strategy) would seem appropriate?