Grantor Trusts: Theory, Drafting, and Application

1 unit

This advanced course provides an intensive study of the grantor trust rules under Subpart E of Subchapter J of the Internal Revenue Code (§§ 671–679) and their central role in modern estate, gift, and generation-skipping transfer (GST) tax planning. Emphasizing both theory and practice, the course explores the statutory framework, regulations, and interpretive authorities governing when a trust’s income is attributed to its grantor, the income and transfer-tax consequences of grantor status, and planning opportunities arising from intentionally defective grantor trusts (IDGTs) and related techniques. Students will engage in hands-on drafting exercises to develop and critique grantor trust provisions, toggling mechanisms, and transactional documents. Case studies and transactional simulations focus on sales to grantor trusts, substitutions of assets, refinancing arrangements, and the coordination of income and transfer tax objectives for clients with taxable estates. The course is designed for students intending to practice in estate, gift, and GST taxation or to represent high-net-worth individuals and family offices in sophisticated wealth-transfer planning. Prerequisites: recommended, but not required: Federal Income Taxation; Estate and Gift Taxation. Assessment: Drafting projects and final examination