A trust that qualifies for the stretch is the beneficiary of a portion of an IRA. There isn’t enough GST exemption available to fully exempt the trust. So the trustee divided the trust into separate (identical) trusts, one with an inclusion ratio of 1 that’s fully GST taxable, and one with an inclusion ratio of 0 that’s fully GST exempt.

The oldest child is the designated beneficiary (the person whose life expectancy is used to determine the annual required distributions).

Since the two trusts are identical, and have the same designated beneficiary, may the trustee aggregate the two trusts and take the annual required distributions first from the GST taxable trust until it’s used up?

Is there any authority on this?