TIRA owned by a parent.
Parent dies after their RBD [required beginning date]
Primary beneficiary: Conduit Trust
Income beneficiaries of conduit trust: 2 adult children of the parent

If the primary beneficiary of a traditional IRA owned by a parent is a conduit trust and there are 2 income beneficiaries of the trust: 1) an adult, disabled son (eligible designated beneficiary) and 2) a non-disabled adult daughter (non-eligible designated beneficiary):

1. Under the new proposed IRS regs, does the trust have to take RMDs in years 1-9 based on the age of the eldest child?

This deals with:

1. Because the disabled child is an eligible designated beneficiary, this child would be eligible for RMDs using his LE.
2. Because the daughter is not an eligible designated beneficiary, she would be subject to the 10-year rule.

Which child’s situation applies to this conduit trust?