Recently, the IRS issued PLR 201310002, granting a number of favorable rulings with respect to the income, estate and gift tax treatment of a Delaware Incomplete Non-Grantor Trust (or a “DING” trust).  A DING is a trust which is (i) not a grantor trust, for income tax purposes, (ii) an incomplete gift, for estate and gift tax purposes, and (iii) sited in a state, such as Delaware, with no tax on capital gain or income accumulated in the trust, the purposes of which is generally to allow a resident of another jurisdiction to shelter such capital gain or accumulated income (such as from the sale of a business) from income tax imposed by the Grantor’s home state.

To read the full article prepared by our Trust Counsel, Jonathan E. Becker, Esquire, please click the following link DING article by Becker Welcome Back, DINGs.