NING and DING Trusts in Estate Planning: Designing ING Trusts to Avoid State Income Tax and Protect Assets

Effective Drafting of Incomplete Gift Non-Grantor Trusts, Jurisdictional Differences, IRS PLRs

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

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Conducted on Tuesday, August 11, 2015

Recorded event now available

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This CLE/CPE course will guide estate planning counsel on the use of NING and DING trusts to reduce or avoid state income taxes. The panel will discuss the implications of IRS private letter rulings (PLRs) and the differences among jurisdictions which allow for incomplete gift non-grantor trusts.


Incomplete gift non-grantor (ING) trusts (NING trusts in Nevada and DING trusts in Delaware) are valuable estate planning tools that can be effective for both state income tax avoidance or reduction and asset protection in certain jurisdictions. ING trusts allow clients to create trusts in states that permit self-settled asset protection trusts to take advantage of tax savings in states with no trust income taxes.

Structuring ING trusts is an advanced planning strategy. Estate planners must carefully draft ING trust documents to balance the twin goals of avoiding a complete gift of assets—and paying the resultant gift tax—while giving up enough control of the assets to avoid state income tax. And while IRS private letter rulings have approved NINGs and DINGs, not all states allow them. New York recently began treating INGs as grantor trusts subject to state income tax; other states may follow suit.

Listen as our authoritative panel of estate planning attorneys discusses the effective use of incomplete gift non-grantor trusts to minimize state income taxes. The panel will outline key drafting considerations, review differences among the key states that allow clients to take advantage of ING trusts, and discuss the IRS PLRs in favor of the technique.



  1. Overview of NING/DING trusts
  2. Drafting NING/DING trusts
  3. Jurisdictional differences
  4. Review of IRS private letter rulings


The panel will review these and other key issues:

  • What guidance can estate planners glean from IRS PLRs?
  • What essential terms must be included to create an effective ING trust?
  • What jurisdictional quirks should planners be aware of when creating ING trusts?


Keebler, Robert
Robert S. Keebler

Keebler & Associates

As a CPA and tax advisor, Mr. Keebler’s practice includes family wealth transfer and preservation planning,...  |  Read More

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

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