Well, you can read the grantor trust rules (IRC §§ 671–679 and Regs) yourself and make a determination, but a non-grantor trust is required to file a 1041 if one of the income thresholds is met.
Otherwise, I believe the only way to get that (67(e)) deduction is to report on a 1041 as a non-grantor trust. They seem to have left deductibility intact with the only limitation being that the expenses must be incurred because of that fact that the property is being held in a trust (or estate).
