Client is a trustee of a family trust that inherited stock in a C corporation at the end of 2019. Client wants to elect S status for the corporation and proceed with a 5 year plan to liquidate the corporation (to out run the B.I.G. taxes). Trust would need to elect to be a QSST or an ESBT to be an eligible S corp shareholder. Client prefers ESBT. Client wishes to make both elections effective 1/1/2020.
Couple of questions:
1. I think both elections can qualify for late election relief under Rev Proc 2013-30, is there anything I am missing here?
2. Has anyone ever done a simultaneous S election and ESBT election? I can't find much online about doing both of these elections at the same time. Are there any issues that you are aware of with this?
Thank you.