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Loophole

DING / NING Non-Grantor Trust (State Tax Avoidance)

Route intangible income to a no-tax state via Delaware/Nevada incomplete non-grantor trust.

Overview

A Delaware or Nevada Incomplete-gift Non-Grantor (DING/NING) trust is treated as a separate taxpayer resident in a no-income-tax state. Fund it with appreciated stock, private business interests, or IP — future income and gain escape California, New York, New Jersey, and Oregon state tax (9–13% savings). Structured to remain incomplete for federal gift purposes so no gift tax is due.

Best fit
High earners in CA / NY / NJ / ORPre-liquidity foundersIP / royalty owners
Estimated impact
9–13% state tax on all trust-held gain and income

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