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October Surprise 2024

Part III – Internal Revenue Service

to ESBT. A trust is eligible to convert from a QSST to an ESBT if it meets the following requi. ements : (1) The trust meets all of the requirements to be an ESBT under § 1361 (e), except for the requirement under § 1361 (e) (1) (B) that the trust not have a QSST election in place under § 1361.