Diana Mite is the owner of 80% of the only class of stock of Watch This, Inc. (WTI). WTI manufactures and sells fireworks. WTI also designs and manages fireworks events. Five of Diana's siblings own the other 20% of the WTI stock. All WTI stockholders are US citizens and a valid S election is in place. WTIs combined annual revenue is above $100 million. Diana will not revoke the S election. She wants her four children to be owners of WTI to remove some of its value from her estate. With the help of her lawyers she has created a trust for the benefit of her four children (ages 19, 22, 25 and 27). None of the children will purchase a trust interest. Diana intends to transfer 10% of WTI stock to the trust along with some minor amounts of cash .

Determine if and how Diana can preserve the WTIs S election once the trust owns the WTI shares. Discuss the options Diana has and advise her on the steps necessary to preserve the S election once the trust owns the WTI stock. Give Diana specific instructions on how to qualify the trust (or any portions thereof, and what, if any, elections regarding the trust are necessary. Explain in detail.