On March 7 the IRS in PLR 201410010 approved another “NING” trust (Nevada Incomplete Gift Non-Grantor Trust), which is incomplete for transfer tax purposes while remaining a non-grantor trust for income tax purposes. This trust, with grantor as beneficiary, allows a non-Nevada residents to benefit from Nevada’s income tax and property laws, avoiding both gift tax and their own state’s income tax.
The original ruling approving the NING was last year’s PLR 201310002. (The NING idea originated with Delaware’s DING, but takes advantage of Nevada’s status as the current first choice for Domestic Asset Protection Trusts.)
This is general information for educational purposes, not to be relied on as specific legal advice.
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