For these distributions: "She has her investments and IRA in revocable living trusts, with each trust having it's own EIN. The recipient's ID number on each 1099 is the trust EIN."

When the IRA is renamed to the Trust as owner, that is complete distribution as a taxable event for her. This might be very ugly. My understanding is you name the Trust as Beneficiary, but do not Rename the IRA so that the Trust is the owner. Trust as Owner = distribution, not sheltered as a divorce renaming event would be.

I found this:

https://www.thebalance.com/ira-trust-a-special-type-of-revocable-trust-for-your-ira-3505399

It clearly describes this as "Trust is the beneficiary." Not the Owner.