Incomplete gift, nongrantor trusts (INGs) were just a recent innovation in a long history stretching back to the decades prior to WWII of clients deploying trusts for their income tax benefits. In recent years, some high tax states have targeted the use of INGS for the state and local tax savings that these structures provided. How are taxpayers in these states responding to these changes? We will look at how ING structures work, how some states seek to invalidate them, and explore some of their remaining uses. We will also look at alternatives to ING structures and how these may be of use to obtain similar benefits.
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Daniel C. Lorenzen, Partner, Venable LLP
