The "owner" has no beneficial interest.I thought I recalled that the owner could withdraw the original contributions (not the earnings) tax free, but I haven't looked that up. Can anyone comment?If so, control of the original contributions (where that money could revert to the owner), seems like a beneficial interest. And transferring that ability to withdraw the original contributions to the parent (from the grandparent) would be a gift. (In which case, is the transfer of ownership as a gift only valued at the original contributions?)I may be all wet on all aspects of this, but I've thought about this on my own before and assumed that's what drove the gift aspect of any such transfer.fin
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