Who is eligible to elect the settlement initiative?
A.2 A taxpayer who received distributions from a CRT or distributive shares or distributions from a pass-through entity that received distributions directly from the CRT is eligible to participate in the settlement initiative. Certain other partners are also eligible. See Q&A 4. The CRT itself and any pass-through entities are not eligible to elect the settlement initiative. Furthermore, the CRT and any TEFRA partnerships do not have to file an election for the taxpayer to be eligible.
