Estate and Trust election 645 terminates
Scenario
Facts:
A. Decedent passes August 20th 2021
B. Decedent had revocable living trust
C. Decedent had a pour-over Will
D. Estate administrator and trustee one and the same
E. Estate on fiscal year
E. Estate made 645 election after appointments
F. Estate holds a qualified plan subject to RMD described in pub 590b - the Beneficiary not an individual and using life expectancy table.
G. Trust has a capital loss carryover
H. Trust has minimal cash balance which generates none or very little income
Circumstances:
The beneficiaries would like to keep the estate open and take advantage of RMD life expectancy table for a non individual for the qualified account. This choice will keep the estate open past the 645 election period to treat the trust as part of the estate. Given the facts above, is the following correct when 645 election terminates on August 19th 2023:
1) trust maintains its existing TIN Under § 1.645-1 as the executor and trustee was appointed before the 645 election.
2) Long term capital loss remains with the trust upon split from the estate. No form or notification to the IRS is required.
3) trust after 645 terminates will have a short year as it will return to calendar year reporting. Even if trust has no income for short tax year 2023, 1041 must file for tax year 2023. Trust will have no reported income from estate for short year as that income was reported under combined 1041 2022 year end return.
3) Taxable Income from RMD taken late in year 2023 to estate will be reported to trust via K1 after close of fiscal year end 2023 which will be reported on trusts 2024 1041.
4) Trust which is now on 2024 calendar year end will issue K1s to beneficiaries who will report on their 2024 1040.
5) inform beneficiaries of the change in reporting the 2024 K1 from estate/trust. For example from reporting 2022 K1 on their 2023 tax return to reporting 2024 K1 on their 2024 return.
6) keeping Qualified plan held in estate is an acceptable reason for keeping estate/trust open for a prolonged period of time 1.641(b)-3
Interested in hearing If above is correct, if not please correct.
Thanks for the input.