Jay A. Soled (Rutgers Business School) & Mitchell Gans (Hofstra), Sales to Grantor Trusts: A Case Study of What the IRS and Congress Can Do to Curb Aggressive Transfer Tax Techniques, 78 Tenn. L. Rev. 973 (2011):

Sales to grantor trusts produce magnificent transfer tax savings. Such savings raise an important policy question: What can the IRS and Congress each do to eliminate this and other transfer tax savings devices that erode the transfer tax base? While this analysis does not pretend to have all the answers, it presents straightforward and practical solutions to many of the problems plaguing the nation’s transfer tax system using sales to grantor trusts as a case study.