A person is a contributor to the trust if the person has made a loan or transfer of property to the trust, either directly or indirectly, in any manner whatever, unless the following conditions are met:

• the person deals at arm's length with the trust at the time of the loan or the transfer;
• the person has not become a majority-interest beneficiary of the trust immediately after the loan or transfer; or
• the person makes the loan at a reasonable interest rate or makes the transfer for a consideration equal to the fair market value (FMV) of the property.