I have an S-corp with two ESBT trusts as shareholders. They are electing this beginning in 2009 and were previously grantor trusts that paid no tax. They will owe tax in 2009 but no estimated payments were due because of the 0 tax due in 2008. The question I have is whether it is ok for the S corp to accrue the distributions to the trusts or if the distributions must be paid out before the end of the year to maintain pro rata distributions. The tax for the trusts won't be due until next year so I'd like to accrue the distributions on the books of the s corp but not sure if this is allowed. Please help me with some authority for this.