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The trustee must give the trusts name, TIN, and address to all payors for the taxable year, and the trustee must file Forms 1099 with the IRS and appropriately attribute the income of the trust among the grantors in proportion to their deemed ownership.
Irrevocable trusts are another type of grantor trust that cannot be changed or dissolved by the Grantor once the trust has been established. These trusts are often used for asset protection and tax planning purposes. For tax purposes, irrevocable trusts can be either grantor trusts or non-grantor trusts.
Grantor trusts are controlled by the grantor, while non-grantor trusts are managed by a trustee (established by the grantor). Grantor trusts provide income and tax benefits to the grantor, while non-grantor trusts do not.
The primary risks with GRATs include the grantor not surviving the trust term, the assets not appreciating as expected, and the administrative complexity and costs associated with managing the trust.
The income the trust generates is taxed to the grantors income tax rate rather than to the trust itself. In this regard, grantor trust rules offer individuals a certain degree of tax protection because tax rates are generally more favorable at the individual level than they are for trusts.

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If a trust is a grantor trust, then the grantor is treated as the owner of the assets, the trust is disregarded as a separate tax entity, and all income is taxed to the grantor.
One of the most popular triggers for grantor trust status is the power of substitution. Under Section 675 of the Code, grantor trust status is created if the grantor holds a power in a nonfiduciary capacity. . .to reacquire the trust corpus by substituting other property of equivalent value.10 Under this
2023-2 changes that. Unless the assets are included in the taxable estate of the original owner (or grantor), the basis doesnt reset. To get the step-up in basis, the assets in the irrevocable trust now must be included in the taxable estate at the time of the grantors death.

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