…a corporation, must be allowed to establish an entity that will be treated as a trust for tax purposes. While the grantor trust rules of IRC Sections 671-679 (Subpart E) are generally drafted using language which assumes 4 EFTA00582951 that an individual is the grantor of a trust, both Subpart E and the regulations thereunder recognize that a corporation may establish a trust and be its grantor.' 2. Treatment of VI Trust as a Non-grantor Trust For the…