26 C.F.R. § 1.678(b)-1 If grantor is treated as the owner.
Title 26 - Internal Revenue
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.
Title 26: Internal Revenue
PART 1—INCOME TAXES
grantors and others treated as substantial owners
§ 1.678(b)-1 If grantor is treated as the owner.