EFTA Document EFTA01452350

have no New York trustees, no properly located in New York, and no New York-source income). Second. the bill would eliminate a loophole" that allows so-called incomplete gift, non-grantor trusts ("INGs" or "DINGs,- if the trusts are created in Delaware) to completely avoid New York income tax; it would do so by making the trust a "grantor trust" for New York income tax purposes - meaning that the creator of the trust would be taxable on the trust's income for New York purposes. even though t