IRS Revenue Ruling 2023-2
https://www.reuters.com/legal/transactional/irs-confirms-that-completed-gifts-grantor-trusts-are-not-eligible-section-1014-2023-06-21/ An irrevocable "grantor trust" is an anomaly under the Code. A "grantor trust" is not recognized as a separate taxpayer for income tax purposes during the lifetime of the creator (commonly referred to as the "grantor" or the "settlor"). All income earned during the grantor's lifetime is reported on the grantor's individual income tax returns. Yet, if the grantor trust is irrevocable, and if the transfers to the trust are deemed to be completed gifts, then upon the death of the grantor, the assets of the grantor trust are not included in the taxable estate of the grantor for estate tax purposes. So, a grantor trust is deemed to be owned by a grantor for income tax purposes, but not for estate tax purposes: thus, the uncertainty over the eligibility of the grantor trust assets for the Code Section 1014 basi...