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@Tiger5 wrote:

you should make sure and document that they both understand the downstream implications of these once-in-a-lifetime elections, having assessed the potential tax impacts beyond the immediate tax year.

 

Please explain future, not understanding?

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This is relevant only if the spouse was a nonresident alien at some point during the tax year in question.  Especially in the case of (g) election, you'd need to consider potential liabilities that may be incurred and reporting as well as disclosure obligations, including information returns such as F.5471, that may need to be met as a result of the election.  The spouse's employment, net worth, potential inheritance, business holdings, future plans, how a separation/divorce will affect their ability to make the same election in the the future, etc. should all be taken into account.  Can't get more specific than this as it would take a training course to scratch the service of alien taxation.