Creating a domestic asset protection trust (DAPT) that both has multijurisdictional contacts and is nonvoidable in whole or in part is easier said than done. There are the state conflict-of-laws issues, a few of which I have touched upon in prior JDSUPRA postings. See https://www.jdsupra.com/legalnews/when-the-parties-to-a-trust-5693362/ and https://www.jdsupra.com/legalnews/uniform-trust-code-utc-and-uniform-9217529/. And then there is the possible applicability of the Full Faith and Credit Clause of the federal constitution that our scrivener would need to contend with. See my prior JDSUPRA posting on that subject: https://www.jdsupra.com/legalnews/the domestic-asset-protection-trust-dap-30858/. In §9.28 of Loring and Rounds: A Trustee’s Handbook (2025), due out in December of 2024, the state and federal conflict-of-laws considerations in the DAPT space have been brought together under one roof. One-stop shopping as it were. The draft of the 2025 version of §9.28 is reproduced in its entirety in the appendix below.