The IDGT RULESCHEAT SHEET
IRC §§671–678, mapped against the estate inclusion tests, on ten pages you can keep next to the drafting file.
Grantor trust status is the easy part. The hard part is proving that the same power that creates income-tax ownership does not pull the trust back into the gross estate. This reference lays both analyses side by side so you can check one against the other before the instrument goes out.
WHAT'S INSIDE
- Every trigger under §§671–678, with the exceptions that switch it off
- A risk map that sorts each power into preferred, usable with caution, fact-dependent, or inconsistent with estate exclusion
- The §675(4)(C) swap-power checklist built to Rev. Rul. 2008-22
- A spousal IDGT answer for SLAT-style designs
- Tax reimbursement rules under Rev. Rul. 2004-64
- A §2035–2042 cross-check for every grantor-trust power
- A 12-step drafting and review checklist
- Primary authorities with current-text links
