State Income Tax Sourcing and Trust Planning Techniques for Individuals
Tuesday, January 26, 2021
4:20 PM - 5:20 PM (PST)
Kevin Ghassomian Akash Sehgal

Join the speakers as they discuss considerations for taxpayers seeking a change of state tax residency and situs planning opportunities through the use of incomplete gift non-grantor trusts (“ING trust”). Topics will include: market sourcing regulation and analysis for taxpayers of various high tax jurisdictions, the anatomy of an ING trust, fiduciary nexus arguments attendant with ING trust distribution committees, the current status of IRS private letter ruling requests, anti-ING trust legislation in New York and proposed legislation in California, recent caselaw addressing the taxation of nongrantor trusts, potential tax shelter arguments, and more. The panel will also discuss the income sourcing rules for taxpayers that change their state of residence from high-tax jurisdictions to no-tax jurisdictions.