The amount elected to be treated as a prior year distribution under IRC Section 663(b):

Should normally be zero since trusts and estates have more favorable tax brackets than do individuals

Is limited to amounts actually paid or credited during the 65 days after the end of the trust's or estate's tax year

Can be more than distributable net income for the tax year in question

Must be consented to by any beneficiary whose K-1 is affected by the election