grantors and others treated as substantial owners
§ 1.678(b)-1 If grantor is treated as the owner.
26 C.F.R. Part 1 — Income Taxes · 2026 edition · updated 2026-10-04 · United States
Section 678(a) does not apply with respect to a power over income, as originally granted or thereafter modified, if the grantor of the trust is treated as the owner under sections 671 to 677, inclusive.
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