In several instances, (8) the entity planned to file Form 8832, electing to
be treated as a corporation, and Form 2553 to be taxed as an S corporation.
RECEIVE IRA distributions over a fixed number of years means the ultimate beneficiaries can continue payments for the remaining fixed number of years the distribution option survives the taxpayer's death.
2632-1(b)(3)(ii), the election statement must (1) identify the trust, (2) specifically describe or otherwise clearly identify the transfers to be covered by the GST trust election and (3) specifically provide that the taxpayer is electing to
have the trust treated as a GST trust for the described transfers.
2632(c)(5)(A)(ii), the transferor is electing to
have the trust treated as a GST trust as defined in Sec.
The net effect of electing to
amortize the market discount for tax-exempt bonds is that the taxpayer can treat the entire gain as a capital transaction (as opposed to a mixture of capital gain or loss and ordinary income).
By electing to
recalculate life expectancy, the payout will be slower during the life of the participant and/or beneficiary.