The months immediately following a client's death create one of the most important income tax planning windows in estate administration. While many practitioners focus on basis step-ups and beneficiary distributions, one election can fundamentally change how post-death income is managed: the Section 645 election.

In this episode, Cary Sinnett sits down with nationally recognized tax expert Bob Keebler to explore how electing to treat a revocable trust and estate as a single taxable entity can create valuable planning opportunities through fiscal year flexibility, income deferral, charitable deduction planning, and more.
Bob explains why he believes the Section 645 election should be the default choice in nearly every revocable trust administration and discusses the rare situations where it may not be appropriate.

What you'll learn:

Why estates receive more favorable income tax treatment than revocable trusts
How the Section 645 election allows a trust to use an estate's fiscal year
Using fiscal year flexibility to defer income and smooth taxable distributions
How the election can effectively stretch certain inherited IRA distributions
Why charitable deductions under IRC Section 642(c) are often more advantageous for estates
The impact of the election on distributable net income (DNI) planning
How the election can improve gain and loss netting in pecuniary funding situations under the Kenan case
The interaction between the Section 645 election and S corporation stock ownership
The limited circumstances where practitioners may intentionally avoid making the election

AICPA Resources:
Chart: Useful Estate and Trust Decision Charts
Podcast: Bob Keebler on Avoiding Costly Estate Planning Mistakes
Resource: Summary and initial thoughts — Changes to opportunity zones
Resource: 2026 Individual, Estate, and Gift Tax Cheat Sheet
Guide: The Adviser's Guide to Financial & Estate Planning - Vol. 4
Program: Estate Planning Certificate Exam

This episode is brought to you by the AICPA's Personal Financial Planning Section, the premier provider of information, tools, advocacy, and guidance for professionals who specialize in providing tax, estate, retirement, risk management and investment planning advice. Also, by the CPA/PFS credential program, which allows CPAs to demonstrate competence and confidence in providing these services to their clients. Visit us online to join our community, gain access to valuable member-only benefits or learn about our PFP certificate program.

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Why Bob Keebler Makes the Section 645 Election Almost Every Time

AICPA Personal Financial Planning (PFP)

Why Bob Keebler Makes the Section 645 Election Almost Every Time