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When Should An Irc Section 645 Election Be Made? Almost Always!
Trusts and Estates Quarterly; Vol. 29, Issue 4 (2023)
During the lifetime of a grantor, the grantor is not deemed a separate taxpayer from the grantor’s revocable trust. As such, the grantor and the trust are considered one-and-the same for income tax purposes, and trust income is reported on the grantor’s personal income tax return. After death, the grantor’s estate and trust (now irrevocable due to the grantor’s death) become separate taxable entities for which separate income tax returns must be filed.
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