You May Have Heard About

How “DINGs” and “NINGs”
Can Save Income Taxes
- - But Do You Know How to Properly
Plan, Structure and Administer Them?

Incomplete Gift, Non-Grantor Trusts (“INGs”) have become the hot, new way to save your clients state income taxes (they’re also known as “DINGs” or “NINGs” for ones sitused in Delaware or Nevada).

While DINGs and NINGs sound simple on the surface, like most estate and tax planning techniques the “devil is in the details” and they have deeper, more complex issues that need to be addressed if they are to be utilized properly.

That’s why we’ve brought in nationally renowned estate planning, tax and trust expert, Edwin P. Morrow, J.D., LL.M., MBA, CFP®, RFC®, to share with you just what you “need to know” to optimize the use of DINGs and NINGs for your clients.

On Part 1 of a special 2-part program series of 90 minutes each, Ed will address the basics of creating DINGs and NINGs:

  • The unique trust structure approved in the key PLRs, including the most recent favorable ruling involving community property
  • Which states are best for using INGs, including when and how much might be saved (Ed will even provide a chart comparing the 50 states plus the District of Columbia!)
  • Overlooked design options to legitimately avoid some state trust residency rules (along with an examination of several recent state and U.S. Supreme Court decisions on the constitutional limits of these residency rules)
  • How some states’ “source income” rules apply, regardless of a taxpayer’s residency
  • How investors can use DINGs and NINGs to minimize the tax hit from Fortune 500 companies’ mega-inversions
  • The overlooked federal income tax benefits possible with such trusts, such as avoiding the 3.8% surtax applicable to passive business owner income, as well as income tax shifting
  • And much more!

In Part 2, Ed will dive deeper into some of the more complex technical issues of DINGs and NINGs, including:

  • How to avoid state income tax for most clients’ largest taxable event – the sale of a closely held business or pass through entities holding real estate and business interests - - due to state “source income” rules (included will be a 50 state chart discussing “source income” and sales of intangibles – another important area that most commentators, charts and articles in this area inexplicably avoid!)
  • Overlooked traps with marital and community property (and joint trusts) and how to avoid them
  • Where’s the comfort level of “relying” on PLRs – what is clearly supported in the tax code, regulations or other substantial authority and what is not?
  • Why NY’s response to DINGs will NOT become widely adopted by other states (and, what loopholes NY left open)
  • Common administration traps that might trip up non-grantor trust status
  • How to exploit IRC §643 regulations to trap capital gains inside the trust for tax purposes, even if they are distributed (and how ESBTs can trap non-capital gains income in trust even if income is distributed)
  • Traps and opportunities with loans, investments and purchases to and from DINGs and NINGs
  • Why politicians love DINGs and NINGs and how they can use them to exploit a little known new tax code section buried deep within the latest PATH Act!
  • How to defer gains via installment sales to DINGs and NINGs at least two years prior to sale of a business (and the traps for installment sales of LLC/partnerships!)
  • How using DINGs and NINGs in conjunction with charitable remainder unitrusts (CRUTs) will often be much, much more tax efficient than ordinary CRUTs (and why you need to know how to avoid the unrelated business income tax or “UBIT” rules
  • And much more!

Join us and Ed for this special 2-part program entitled, “DINGs and NINGs: Technical and Planning Issues”.

  • Program Title: DINGs and NINGs: Technical and Planning Issues
  • Speaker:
  • Duration: 90 Minutes each

Edwin P. Morrow III

J.D., LL.M., MBA, CFP®, CM&AA®
Edwin P. Morrow III

Ed is currently the Regional Wealth Strategist for the eastern U.S. for U.S. Bank’s Private Wealth Management, where he concentrates on thought leadership and planning ideas for high net worth clientele in tax, asset protection and estate planning areas. Previously, he was a Director in Key Private Bank’s Family Wealth Advisory Group, analyzing tax, trust and estate planning needs of ultra high net worth clients of Key Private Bank nationwide in conjunction with local teams of credentialled financial planners, trust officers, investment specialists and private bankers.

Ed was previously in private law practice working in taxation, probate, estate and business planning. Other experience includes research and writing of legal memoranda for the U.S. District Court of Portland, Oregon as a law clerk. He is a Fellow of the American College of Trust and Estate Counsel (ACTEC). He is a Board Certified Specialist (through the Ohio State Bar Assn) in Estate Planning, Trust and Probate Law, a Certified Financial Planner (CFP) professional and a Certified Merger & Acquisition Advisor (CM&AA). He is also a Non-Public Arbitrator for the Financial Industry Regulatory Authority (FINRA) and a member of the Editorial Advisory Board of the Probate Law Journal of Ohio.

Ed is a frequent speaker at CLE/CPE courses on asset protection, tax and financial and estate planning topics, and recently co-authored, with Stephan Leimberg, Paul Hood, Martin Shenkman and Jay Katz, the 18th Edition of The Tools and Techniques of Estate Planning, a 997-page practice-based resource on estate planning.


  • Bachelor of Arts (B.A.), History, Stetson University
  • Juris Doctorate (J.D.), Northwestern School of Law at Lewis & Clark College
  • Masters of Law (LL.M.) in Tax Law, Capital University Law School
  • Masters of Business Administration (MBA), Xavier University

Professional Accreditations:

  • Licensed to practice in all Ohio courts, U.S. District Court of Southern Ohio and U.S. Tax Court
  • Board Certified Specialist  through Ohio State Bar Association in Estate Planning, Trust and Probate Law
  • Certified Financial Planner (CFP®), Certified Merger and Acquisition Advisor (CM&AA®)
  • Non-Public Arbitrator for the Financial Industry Regulatory Authority (FINRA)


The Ultimate Estate Planner, Inc. and the presenter are not registered Continuing Education Sponsors and this program is not pre-approved for continuing education credit for any state or regulatory agency.

However, please note that each program includes a Certificate of Completion and, depending on the license and the regulatory agency for which governs a participant’s CE credit, some professionals may be able to self-report his or her participation and receive credit. It is the responsibility of the participant to complete any process necessary to seek self-reported CE credit for his or her participation. By registering for a teleconference (or purchasing on On-Demand program), you understand that CE credit is not guaranteed or warranted by the presenter or The Ultimate Estate Planner, Inc.

Leave a Review

If you have purchased this product and would like to leave a review for others, please comment below.