Yes, I am a sibling of the decedent, and he passed away prior to reaching his RBD.
I read an article that seemed to indicate that if you decide to do the stretch distribution you cannot later switch to the 10 year rule option. If correct, I guess that means that for example if you take a stretch distribution in the 1st year after the decedent's passing you cannot later decide to defer further distributions until year 10.
I see your point that this would not preclude a beneficiary from taking their distributions over a 10 year period, by taking more than the RMD each year. And so, a beneficiary whose life expectancy was let's say 21 years, could instead complete the distributions in 10 years.
It seems like there is some benefit to doing the stretch and taking the RMD only (that is, not topping out to the current tax bracket). Let's say money taken out of the IRA is placed in investments whose earnings would be taxed at the favorable LTCG or qualified dividend rate. Earnings on that distribution would be taxed year after year. If you hadn't taken additional money out of the IRA to top out to your current tax bracket, that principal would continue to grow tax free until taken from the IRA as a distribution. I am probably missing something in my thinking on this.
