@trust812 , definitely consult with the attorney because, as I read what you posted, there seems to me to be some ambiguity in the trust language. As used in the tax code, "qualified retirement plan" generally refers to qualified retirement accounts other than IRAs, so it's not clear that what you posted applies to distributions from IRAs. Also, if the section that you quoted does apply to IRAs, it seems to say that only you and your sister are to receive the income from the distributions from the IRA to the trust unless no descendants remain. If the girlfriend is a beneficiary who is to receive income from the IRA while there are still living decendents, it seems that there must be annual RMDs based on the girlfriend's age, resulting in a distribution period of substantially less than 10 years. If your father died in 2024, beneficiary RMDs would begin in 2025 and if the girlfriend will be age 90 in 2025, that would mean RMDs would be based on the girlfriend's life expectancy of 5.7 years even under the 10-year rule. If the girlfriend is not to receive distributions, it might be that the annual RMDs would instead be based on your life-expectancy as the oldest beneficiary under the 10-year rule, but I haven't spent much time understanding the SECURE Act requirements for RMDs as they pertain to trusts with multiple beneficiaries, requirements that are a bit different from pre-SECURE Act requirements.
The trust does not satisfy the requirement for look-through until the IRA custodian is provided with by October 31 of the year following the year of death the documentation required by the custodian under these circumstances.
