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Section 179 expense not allocated to a shareholder who is an estate or trust

Each individual shareholder's pro rata share of Section 179 expense is reported on Schedule K-1, Box 11. However, per Form 1120-S instructions for Box 11:
Do not complete Box 11 of Schedule K-1 for any shareholder that is an estate or trust.
 The Section 179 expense for the remaining shareholders isn't adjusted for the amount that would've been allocated to the estate or trust.
If the trust is a grantor trust, or a qualified Subchapter S trust (QSST), the S Corporation stock is treated as owned by the beneficiary. The Section 179 expense presumably should be allowed by the deemed owners. UltraTax CS allocates Section 179 expense to shareholders whose entity type is Grantor Trust / QSST.
Per IRC Regulation 1.179-1(f)(3), the S Corporation's basis in Section 179 property shall not be reduced to reflect any portion of the Section 179 expense allocable to the trust or estate. The S Corporation can claim a depreciation deduction for the amount of Section 179 that would have been allocated to the trust or estate shareholder.

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