@Jim-from-Ohio 

Yes, it's all been a moving target. There are some proposed rules that were expected to have been put in place in 2024, but I haven't seen anything new released and it's likely too late this year for anything to be issued now. Of course, it could be issued retroactively but also waived for 2020-2024. They're done that in the past with the RMD penalties while trying to decide which mechanism accomplishes the new rules (IRS Notice 2024-35). This is why you'll see the media start to issue articles about, "New Rules in 2025 for Inherited IRA Accounts" but they are not new rules. They are an expiration of the transition relief.

I'm pretty sure the provision this scenario falls under hasn't changed between the SECURE Acts. Here's how it currently stands, as I've been following it. We're going to assume everything up to this point has been done properly (didn't own over 5% of the company) and that this was a recent death, so it falls under SECURE Act 2.0, where there is any difference.

This non-spouse and noneligible designated individual beneficiary inherited from the parent. The account holder for this account never reached their RBD (required beginning date), so no RMD requirement exists. Death doesn't substitute for retirement. That's what makes this unusual despite the decedent's age.

If you search, you'll see wording such as:

"and on or after the employee’s (or IRA owner’s) required beginning date"

And for reference:

https://www.journalofaccountancy.com/issues/2023/apr/beneficiary-iras-a-guide-to-the-rmd-maze.html

Also, IRS Pub 590-B:

Payment under the 10-year rule.

If the IRA owner dies before the required beginning date and the 10-year rule applies, no distribution is required for any year before the 10th year.