The same three questions decide almost every case: does it save estate tax, does it save income tax, and can you still get to the money.
At a Glance
Each column links to a full guide: SLAT · NING / DING · Completed Gift Non-Grantor.
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| SLAT | NING / DING | Completed Gift Non-Grantor | |
|---|---|---|---|
| Gift Treatment | Completed | Incomplete — by design | Completed |
| Uses Lifetime Exemption | Yes | No | Yes |
| Removes Assets From Estate | Yes | No — stays in your estate | Yes |
| Who Pays Income Tax | You, the grantor — which lets the trust grow undiminished | The trust, in a no-tax state | The trust, potentially in no state at all |
| State Income Tax Savings | None | Yes — but not for NY or CA residents | Yes, if the exemption tests are met |
| Grantor as Beneficiary | No — prohibited | Yes | No — prohibited |
| Access to the Assets | Indirect, through your spouse and descendants | You may be a beneficiary, but a distribution committee must approve | Indirect, through your spouse and descendants |
| Typically Dynastic (GST) | Yes | No | Yes |
| Where It Can Be Formed | Any state | NV, DE, NH, WY, SD and similar | Any state |
| Trustee Requirement | Flexible — no professional trustee needed | Out-of-state trustee required, typically professional | Out-of-state trustee required for the income tax benefit |
| Primary Objective | Estate tax, with retained indirect access | State income tax and asset protection | Estate tax and state income tax together |
Choosing
Start with what you are actually worried about. If it is estate tax, the incomplete gift trust is off the table immediately — it leaves everything in your estate. If it is state income tax on a coming gain, the SLAT does nothing for you. If it is both, the completed gift non-grantor trust is built for exactly that.
Then ask about access. The SLAT and the completed gift trust both prohibit you as a beneficiary; access runs indirectly through your spouse. Only the NING/DING lets you be a beneficiary of your own trust — at the price of a distribution committee standing between you and the money.
Then run the arithmetic. The SLAT's grantor-trust status is an annual, exemption-free subsidy to the trust; the non-grantor structures give that up in exchange for state income tax savings. Which side of that trade wins is a calculation, not a preference — the size of the expected gain usually decides it.
And remember they combine. The most common pattern among substantial estates is a SLAT for the capital the family may need, plus a completed gift non-grantor trust for the asset with the gain coming. A NING or DING typically joins only after the exemption is fully used, since it consumes none.
Plan Today
Which structure fits depends on facts no article can guess at. A conversation costs nothing and usually settles the question quickly.
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