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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.

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