Client Alerts

PLR 201310002 and its Implications for DING Trusts

On March 8, 2013, the IRS released PLR 201310002, another favorable ruling addressing the gift and income tax consequences of a so-called “DING trust” (The acronym stands for Delaware Incomplete Gift Non-Grantor Trust). If the trust is created in a state, such as Delaware, that does not tax income and capital gains accumulated in the trust, the trust can be a powerful state income tax planning vehicle for settlors living in states that would not tax the trust’s accumulated income and capital gains merely because the settlor resides in that state or because of some other connection between the trust and the settlor’s home state.

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