
AICPA Personal Financial Planning · 2026-07-24 · 20 min
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.