as a grantor trust, I can't come up with a situation where the fees would be deductible currently. prior to 2018, only the amount that exceeded 2% of adjusted gross income would have been deductible if a taxpayer itemized (IRC sec. 67). tax law changes effective for 2018-2025 eliminated this deduction for federal income tax purposes. some states may still allow the deduction.
Note. Fiduciary fees are allowable
under section 67(e) if they are costs that
are paid or incurred in connection with
the administration of an estate or a
non-grantor trust that would not have
been incurred if the property were not
held in such estate or trust. See Final
Regulation - TD9918 and Regulations
section 1.67-4 for more information.
even under 67(e) for non-grantor trusts only costs that are paid or incurred in connection with the administration of the estate or trust that would not have been incurred if the property were not held in such estate or trust are deductible
https://www.govinfo.gov/content/pkg/FR-2020-10-19/pdf/2020-21162.pdf
https://www.law.cornell.edu/cfr/text/26/1.67-4
