0304004 Informal Interpretation

If the disbursement to the settlor are from the corpus of the trust, this is a reversionary interest.

Update July 2014: This is no longer the position of the PNO. A distribution of anything other than cash (i.e., voting securities, assets, non-corporate interests) to the settlor of a GRAT is a potentially reportable acquisition, but it does not constitute a reversionary interest in the trust. Only if the settlor will receive all or part of the corpus of the trust at the end of the term of the GRAT, would he be deemed to have a reversionary interest in it.