Much of the main focus for the more recent notices has been to provide clarity and resolve EDB (eligible designated beneficiaries) and "beneficiaries of beneficiaries" mechanisms. The follow up from the comments reviewed that also led to the transition relief has mostly reiterated that the 2002 policies are still in place, only the timeframes are different, in many places.

"Since it was first added to the Code, section 401(a)(9) has always included the concept of a required beginning date, under which, once required minimum distributions began to either an employee or designated beneficiary, they were required to continue until the employee's entire interest under the plan was fully distributed, and these regulations retain this requirement. There is little indication in section 401 of the SECURE Act to suggest that Congress intended to allow distributions of an employee's account to temporarily cease for up to 9 years once annual required minimum distributions have begun."

"provides rules for determining the required beginning date for distributions and whether distributions are treated as having begun during an employee's lifetime. These rules are based on the rules in the 2002 final regulations, except that the rules have been updated to reflect the amendments to the required beginning date made by section 114 of the SECURE Act and section 107 of the SECURE 2.0 Act."

(my emphases)

As noted, pertinent details in this example scenario are:

Employee did not own 5% of company

Employee was still employed at the employer with the qualified plan

Employee died before reaching RBD on date of death

Taxpayer is not an eligible designated beneficiary

The 401(k) administrator did a direct trustee-to-trustee transfer to an inherited IRA account

The date of death falls under the 10-year rule