The transfer of assets by gift, sale or loan to an irrevocable dynasty trust, which is a grantor trust for income tax purposes, has become a cornerstone of the sophisticated wealth transfer scheme.1 As a grantor trust, even if the property has been transferred from the property taxable for gift, estate and generation-leave transfer (GST) tax purposes and the trust is, in fact, the legal owner of the transferred asset, the grantor is still is also considered as the owner of those properties for
