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—Whether the grantor will be considered the owner of any portion of a transfer in trust under §§ 673 to 677 that is purported to be an incomplete gift under § 2511, specifically including, but not limited to, a transfer to a trust providing for distributions at the direction of a committee to the donor and the

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https://www.irs.gov/irb/2025-01_IRB

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https://www.irs.gov/instructions/i1120f

709, was released announcing that the Department of the Treasury and the IRS intend to issue proposed regulations providing that certain borrow fees, as defined in the notice, are sourced based on the residence of the recipient