however, the IRS reached the opposite result on facts similar to those in Rothstein. That is, the IRS held that the acquisition of the trust's property by the grantor in exchange for a note could not be a sale because the grantor was both the maker and owner of the note. As a result, the grantor did not receive a new cost basis in the stock purchased from the trust. The IRS has explicitly stated that it will not follow the Second Circuit's decision in Rothstein. Indeed, many estate planners rely heavily on Rev. Rul. 85-13's conclusions for a variety of estate planning techniques involving sales to grantor trusts. Consequently, the lasting impact of the Rothstein decision may prove negligible. Even if disregarded for federal income tax purposes, states may not disregard a wholly grantor trust for certain purposes. For example, Pennsylvania varies from federal law regarding grantor trusts and imposes state income tax on grantor trusts according to the same personal income tax rules that apply to irrevocable trusts, unless the grantor trust is a revocable trust. © For some non-income tax purposes (e.g., sales tax), a wholly grantor trust that is disregarded for federal income tax purposes may be respected as the owner of the trust's corpus by some Foreign Tax Planning Considerations Practitioners should be aware that foreign countries may not treat U.S. grantor trusts as disregarded entities. As noted below, a wholly grantor trust is treated as a separate entity for Canadian tax purposes. Various planning opportunities may arise as a result of such divergent treatment. Conduit Financing. Treasury has proposed respecting DREs in an attempt to combat perceived tax avoidance achieved through the use of multiple-party financing transactions. © In general, a financing arrangement is a series of transactions in which one person advances money or other property or grants rights to use property and another person receives money or other property or rights to use property, the