evidence: For any grantor trust that is not fully revocable, the Biden proposal would treat an asset transfer between the trust and you as the grantor as regarded for income tax purposes. That means taxable. That will make a basis step up on assets inside trusts impossible to achieve. Also, swapping to revise or restructure your estate plan will be impossible. For example, you may have put a business asset into a trust and named certain beneficiaries, the son running the business. Years later, your son changed his mind and wanted to do something completely different. Your daughter, who had nothing to do with the business when the trust was created, is now running the business. Under current law, you can swap the business outside of the trust back into your name, and put different assets in the trust. Then you can do a new plan to get the business to your daughter. You lose a lot of flexibility for personal planning reasons, not just the basic step up with the Biden change.