It would only be a problem if a capital gains tax is imposed on the CE. Many experts don't believe there will be one, but others say there will be. The trust eliminates that risk. If the trust isn't in place and the CE is done in one's personal name, or in the name of a statutory business entity, then the capital gains tax may apply. If the CE is allowed to proceed without any tax on ANY of the currency holders, then it is not an issue. Then the trust is just an excellent instrument for other types of asset protection, for prevention of future tax filings on income, for efficiency in organization and distribution, and for the best in estate planning.