We have a grandfathered GST trust (created and irrevocable before 1985). We're planning to change the trust situs and change the trustee. However, we don't want to lose the grandfather status by doing the modifications. I looked at Treas. Reg. Section 26.2601-1(b), and none of the four safe harbor provisions appear to speak directly to the issue.
I would appreciate any thoughts, pointers, or comments on whether the two proposed modifications would throw the grandfathered status out the window. Thank you!