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SLANT — SLAT + NING Hybrid

Spousal access + state income-tax elimination in one non-grantor trust.

Overview

A SLANT combines the estate-freeze and spousal-access features of a SLAT with the state-income-tax elimination of a NING (non-grantor, incomplete-gift, Nevada/Delaware trust). Structured so the grantor's spouse is a discretionary beneficiary, while the trust itself is a non-grantor entity domiciled in a no-income-tax state. Used by high-earners in CA/NY/NJ with concentrated pre-sale positions.

Best fit
Founders pre-liquidity in high-tax states$10M+ estatesConcentrated stock holders
Estimated impact
Eliminate 9–13% state tax on trust income + estate freeze

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