In an increasingly adverse tax environment, taxpayers and their advisors are planning creatively to mitigate their liability exposure. One tool that a taxpayer can use is a Delaware incomplete non-grantor (DING) trust. DING trusts are sitused in jurisdictions that don’t tax the income and capital gains of a non-grantor trust.1 Individual taxpayers who are domiciled in states with high income tax rates use DING trusts to avoid state income tax imposed by their respective domiciles. In ...

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