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Kaestner Family Trust opinion: Grappling with the patchwork of state laws

Inside Deloitte

In this installment of Inside Deloitte, Michael S. Canfield discusses the Supreme Court’s decision in North Carolina Department of Revenue v. Kaestner Family Trust.


On June 21, the US Supreme Court, in Kaestner Family Trust, held that a North Carolina statute that imposes income tax on all trusts with a beneficiary who resides in the state, violated the due process clause of the US Constitution as applied.1 This article analyzes the Supreme Court’s opinion, discusses its immediate consequences in North Carolina, and explores the extent to which the opinion might extend to other states’ laws regarding the income taxation of trusts.

If you have questions regarding this edition of Inside Deloitte, please contact:

Michael S. Canfield, senior manager, Deloitte Tax LLP


1 North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, 588 U.S. ___ (2019).

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