Generally, as calendar year taxpayers prepare to file their 2020 income tax returns during this 2021 filing season, there is not a lot of tax planning that one can do for the 2020 tax year as it has come and gone. There are, however, a few exceptions, such as the ability to make contributions to an individual retirement account or a health savings account during 2021 and to deduct such contribution for the 2020 tax year. Trustees of non-grantor trusts also have an opportunity to take actions during 2021 that may reduce the trust’s 2020 income tax liability. Such opportunity exists under IRC Section 663(b). IRC Section 663(b) allows a trustee to elect to treat distributions made during the first 65 days of the current tax year as distributions made during the immediately preceding tax year.