Incomplete Gift Non-Grantor Trusts: Latest Developments and Private Letter Rulings

Leveraging DINGs Into NINGs for Savings in High State Tax Rate Jurisdictions

Recording of a 90-minute CLE/CPE webinar with Q&A

Conducted on Wednesday, July 24, 2013

Recorded event now available

or call 1-800-926-7926
Course Materials

This teleconference will focus on the benefits of NINGs as a state tax savings vehicle, and discuss the implications of the recent private letter rulings (PLR), how they differ from DINGs, and navigating the differences between jurisdictions which allow for incomplete gift non-grantor trusts.


Incomplete gift non-grantor trusts are a useful tool for savings in jurisdictions with high state tax rates. The trust may be set up in any state that permits self-settled asset protection trusts, which allow the settlor to retain certain powers in a self-settled asset protection trust, and where no fiduciary income tax is imposed on its trusts.

In March 2013, PLR 20131002 approved NING trusts under Nevada law, opening the doors for counsel to utilize this planning tool for clients residing in jurisdictions with similarly high state income tax rates.

By using a NING trust, clients with a low-basis asset to sell or with significant assets that would not be considered source income in their high-rate domicile are now able to realize significant state income tax savings.

Listen as our panel of estate planning attorneys reviews recent PLRs approving NINGs, discusses the benefits of NINGs, which clients are most suited for this income tax planning tool, and identifies jurisdictional distinctions for incomplete gift non-grantor trusts.



  1. Opportunities with DINGs and NINGs
  2. Overview of structure
  3. State tax issues
  4. Federal tax issues
  5. Analysis of PLR 201310002
  6. Asset protection and NINGs
  7. Additional factors to consider
  8. Best practices and pitfalls to avoid


The panel will review these and other key questions:

  • How does PLR 201310002 impact incomplete gift trusts?
  • How is a NING different from a DING?
  • How does a NING trust work and which clients are most suited for this income tax planning tool?
  • Why does a NING trust work for domiciliaries of some states but not others?
  • Why did the trust which was the subject of PLR 201310002 have to be formed in Nevada?
  • What are the essential terms of a NING trust?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Oshins, Steven
Steven J. Oshins

Oshins & Associates

Mr. Oshins' practice focuses on estate planning and asset protection. He was named Las Vegas Trusts and Estates...  |  Read More

William D. Lipkind
William D. Lipkind

Lampf Lipkind Prupis & Petigrow

He is a Founding Member of the firm, specializing in taxation and estate planning. Among other publications, he is the...  |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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