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Check out the notice in the federal register for the actual rule text. Online "experts" often skip over some parts, or are maybe even AI generated pieces. What is most often missed in general public discussions is the entity type can also be a trigger no matter the quantity of filings. And the often discussed change from counting per form type to the aggregate of the specific types. The reality is, one must treat it as efile being required unless they are sure they meet the exceptions. If in doubt, efile.

Section 645 is one of the shortest sections of the code. Anyone working with estates should be aware of it.