Certain revocable trusts treated as part of estate

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Title 26—INTERNAL REVENUE CODE > Subtitle A—Income Taxes > CHAPTER 1—NORMAL TAXES AND SURTAXES > Subchapter J—Estates, Trusts, Beneficiaries, and Decedents > PART I—ESTATES, TRUSTS, AND BENEFICIARIES > Subpart A—General Rules for Taxation of Estates and Trusts

This text was captured on Sep 16, 2026. It is a snapshot, not a live feed, so check the official code before relying on it.

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For purposes of this subtitle, if both the executor (if any) of an estate and the trustee of a qualified revocable trust elect the treatment provided in this section, such trust shall be treated and taxed as part of such estate (and not as a separate trust) for all taxable years of the estate ending after the date of the decedent’s death and before the applicable date.

(Added Pub. L. 105–34, title XIII, § 1305(a) , Aug. 5, 1997 , 111 Stat. 1040 , § 646; renumbered § 645, Pub. L. 105–206, title VI, § 6013(a)(1) , July 22, 1998 , 112 Stat. 819 .)

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Certain revocable trusts treated as part of estate · 26 U.S.C. § 645 | Frix