Evolution of the Lender Structure: Deduction of Investment Management Fees

Overview

The use of a specific ownership structure to provide for the deduction of investment management fees has evolved since 1941 to most recently in 2018 when guidance was provided by the U.S. Tax Court in determining whether the activities of a family investment management company constitute a trade or business. This article walks through details of that evolution and provides guidance on implementing a Lender-Type structure through the use of a Private Trust Company.

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