Taxation

Ca. Tax Lawyer VOLUME 34, 2025 ANNUAL ISSUE

CALIFORNIA’S ANTI-ING TRUST STATUTE COMES WITH STRANGE DRAFTING CHOICES, PLANNING OPPORTUNITIES, LANDMINES, AND APPARENT ERRORS

AUTHOR1

Mark Mullin

On July 10, 2023, California enacted SB-131.2 The bill implemented RTC § 17082 (retroactive to January 1, 2023), aiming to shut down the incomplete gift nongrantor (ING) trust technique. This technique was used by some California-resident high net worth individuals to reduce California income taxes on certain kinds of income (such as gain from most sales of corporate stock).

However, several strange decisions in RTC § 17082’s drafting permit interesting workarounds and create surprising traps. For example, certain IRC § 679 trusts might allow California-only ING trusts to still save state income taxes, many trusts may be "surprise" ING trusts, the charitable ING exception provided by RTC § 17082 might not work, and it’s not clear whether the statute makes ING trusts into true grantor trusts for California purposes.

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