Why Bob Keebler Makes the Section 645 Election Almost Every Time

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. Subscribe to the PFP Podcast channel at Libsyn to find all the latest episodes or search "AICPA Personal Financial Planning" on your favorite podcast app.