Section 645 Election

However information reporting requirements under section 6048 applicable to.

Section 645 election. The applicable date is october 20 2004 the day that is two years after a s date of death. Trust and that the election result in a u s. This election allows a qrt to be treated and taxed for income tax purposes as part of its related estate during the election period.

For purposes of this subtitle if both the executor if any of an estate and the trustee of a qualified revocable trust elect the treatment provided in this section such trust shall be treated and taxed as part of such estate and not as a separate trust for all taxable years of the estate ending after the date of the decedent s death and before the applicable date. Advantages of making the election. Trust the preamble to the final treasury regulations states that the requirement that a qualified revocable trust be a u s.

Generally estates have the ability to elect a fiscal year end or a calendar year end whereas trusts default to a calendar year end. Once the election is made it cannot be revoked. A taxpayer identification number must be obtained by both the electing qrt and the related estate.

Irc 645 provides an irrevocable election to treat a qualified revocable trust as part of the decedent s estate for federal income tax purposes. Certain revocable trusts treated as part of estate. Well a 645 election allows the executor of an estate and the trustee of a revocable trust to elect to treat the estate and the trust as one for tax purposes.

You meet with your trusted advisor and they ask you if you would like to make a 645 election and you think what is that. A section 645 election is available to a revocable non u s. 645 election allows the trustee and the executor to effectively combine a qrt and an estate into one tax return filed as an estate.

Form 8855 is used to make a section 645 election which election allows a qualified revocable trust to be treated and taxed for income tax purposes as part of its. When the election is made by the executor and trustee tax advantages available to an estate are available to the trust. The election must be made on irs form 8855 election to treat a qualified revocable trust as part of an estate by the due date including extensions of the estate s initial income tax return.