Revocable Living Trust and 645 Election

Client had a revocable living trust that housed every asset he owned. He passed away, and the trust became irrevocable on date of death. The estate in its entirety is valued at less than $500K. I would like to file a Section 645 election but have several questions.

1. The attorney filed for and acquired a TIN for "Joe Taxpayer Rvoc Tr Dated 04-08-2001" (not an estate TIN). Does this make any difference?

2. If the estate does not have a TIN, I assume the trust is considered the "filing trust" and Part 1 and Part 3 of form 8855 have the exact same information...ie Joe Taxpayer Rvoc Tr dated... with the exact same EIN. Is this correct?

3. Is the type of entity prior to the election a "Domestic estate" or "domestic trust".....or both....my software allowed both to be checked.

4. Can the form 8855 be e-filed and if so, how do I obtain the signatures?

5. If the 8855 must be paper filed, is there a transmittal form that should be sent along?

6. Assume paper filing is required, do you think it would be a good idea to also attach a PDF of the 8855 with the original e-filed 1041?

Thanks in advance for any clarifications you can provide.

1. I would use the name that the attorney used to get the EIN on the 1041 and the 8855.

2. Yes and yes

3. Trust

4. I paper file the 8855. You can attach a cover letter if you wish.

6. up to you

Client had a revocable living trust that housed every asset he owned

Perhaps the attorney didn't get an EIN for the estate because all income/expenses including attorney fees will be for the administration of the trust. The estate would not have a filing requirement (income less than $600). So why the need for a 645 election?

Fiscal year is probably the number one reason I do the 645 election, or if there is rental property.

Estate EIN goes in box C, trust TIN goes in box G. How does that work with no Estate EIN?
No rental RE in estate according to OP.
Is the fiscal year supposed to replace an extension in OP's case?
I do very few estate 1041's and I'd like to understand why this is being done. It may be advantageous in the future. I just don't see what the OP is trying to accomplish.

Estate EIN goes in box C, trust TIN goes in box G. How does that work with no Estate EIN?
No rental RE in estate according to OP.
Is the fiscal year supposed to replace an extension in OP's case?
I do very few estate 1041's and I'd like to understand why this is being done. It may be advantageous in the future. I just don't see what the OP is trying to accomplish.

There is rental property but it is in the name of the trust. I wanted to extend the due date using a fiscal year (instead of a calendar year), and I wanted the $600 exemption instead of the $300 exemption. Plus the paperwork involved to do all of this is only one page....and should be simple to fill out, except the idea of no estate EIN tripped me up!

Somebody who dies in the second half of the year will probably end up filing two 1041's. With a fiscal year election, you might get away with one return. You also will push any taxable income into the next tax year.

No rental losses are allowed in a trust unless material participation. I believe that if there is a loss, the unused loss is added to basis. I would have to look that up to be sure. The 645 election gets you active participation standards, and usually a deductible rental loss. There is no reason to do a 645 election just to get an additional exemption, that is never *used* in the final year. In the final year of a 1041, all income/deductions etc are distributed and taxed to the beneficiaries. Hence, the exemption amount is N/A. The exemption amount of a complex trust is $100