Given that the trust document did not specify that the sub-trusts were to be created immediately upon the death of the decedent, it seems that the separate account rules would not apply. Therefore, it would seem that the age of the oldest beneficiary would be used to determine annual RMDs for all beneficiaries. Because the oldest beneficiary will reach age 91 in 2025, the year that beneficiary RMDs must begin, the life expectancy factor for 2025 would be 5.3, reduced by 1 each subsequent year. This would mean that the IRA would be fully drained by the end of 2030.
