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Single family offices should understand Lender Bagel structures and consider using them if they are not already. Knowledge of this structure has spread like wildfire since the landmark case, Lender Management LLC v. Comm’s. This article equips the reader with an understanding of the core principles of what Lender Bagel structures and how to investigate if it will help the family. With the proper structure, families can harvest the tax savings and other benefits that are available.

Cryptocurrency has revolutionized the financial markets but also created tax traps for the unwary investor. Building on proposed regulations issued in 2023, the IRS has increased its oversight of cryptocurrency transactions by requiring brokers, beginning in 2025, to report investor sales and exchanges in connection with such transactions. Taxpayers not complying with these requirements may face penalties based on accuracy of reporting. For federal tax purposes and regulatory compliance, any form of virtual currency is treated as property and not cash.

In this 10-minute interview, attorney Jordan Bergmann of Foley & Lardner joins Brian Lucareli to discuss qualified business stock (QSBS). During the interview, Jordan defined QSBS and the tax benefits they provide and how family offices can take advantage of the QSBS as part of their wealth management and tax planning strategy.

The importance of meeting U.S. tax and reporting deadlines cannot be overstated. With the IRS continuing to strengthen its efforts to enforce compliance with initiatives specifically targeting foreign information reporting, this U.S. reporting checklist by Kozusko Harris Duncan can help family advisers and trustees of foreign trusts determine what if any U.S. reporting will be due.

The issue of concentrated low-basis holdings is a challenge that has vexed wealth managers and their clients for decades. Put simply, if a large majority of your wealth is concentrated in a single position, should you sell some of it and move the proceeds to a more diversified portfolio of investments? However, the sale position oftentimes carries enormous unrealized capital gains with a huge tax liability. But over the years, new ways of looking at the concentrated position have evolved to provide a more robust and meaningful solution.

With an unprecedented $80 billion additional funding allocated for the Internal Revenue Service (IRS), there will be an expected 3,700 new agents hired as part of ramping up audits of the largest and most complex partnership returns and other tax enforcement initiatives. There will also be more focus on high income individuals, foreign bank accounts, and the Employee Retention Credit as the IRS pursues its existing authorities.

Generative artificial intelligence (AI), once seen as a vision of tomorrow, has rapidly advanced to become an established part of the day-to-day operations for organizations in every industry. Like any other emerging technology, the time to think about how AI will impact the future of business—including the tax function—is now. By integrating AI gradually and effectively implementing automation technology, organizations and tax professionals can benefit from enhanced efficiency, optimized operating models, advanced data insights, and improved talent acquisition and retention.

In times of significant change, it is easy to become paralyzed by uncertainty and indecision. However, such changes are inevitably accompanied by new opportunities. In this Wealth Planning Outlook, insights—and action items—are provided on the most vital planning issues amid epochal technological innovation in artificial intelligence (AI); an uncertain, though in many ways familiar, political, and tax landscape; and rapidly evolving attitudes on the greater meaning of wealth and legacy.

Over the past 15 years, the IRS has attempted to ramp up its scrutiny of wealthy individuals. With billions in new funding promised under the Inflation Reduction Act, the IRS has announced additional tax enforcement efforts focused on the wealthiest filers, including high-income individuals, partnerships, and large corporations. Attorney Erin Lasenby discusses some of these enforcement efforts and the filers that would be affected by each. With the revitalized efforts, the targeted filers should be prepared for the IRS shifting their audit attention to them.

Tax planning is as essential as ever for taxpayers looking to manage cash flow while paying the least amount of taxes possible over time. It’s time for individuals, business owners, and family offices to review their current tax situations to identify opportunities for reducing, deferring, or accelerating their tax obligations. This article, which is based on the U.S. federal laws and policies in effect as of the publication date, provides the information that will help you with your tax planning.