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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. With a review of the details of tha...

In December of 2017, the U.S. Tax Court decided in the Lender Management, LLC v. Commissioner case that deductions that were part of a taxpayer’s trade or business were deductible under Section 162; however, deductions under Section 212 were suspended through tax year 2025. Following the suspension of the 2-percent miscellaneous itemized deduc...

As family offices have grown in number, size and sophistication, they have increasingly looked to invest directly. Largely, the pursuit of direct investing opportunities has been driven by several factors, including the desire for increased control, better alignment of interests, reduced fees and expenses, and higher returns. While the appeal of di...

Family offices, much like the families that need them, are works in progress. You can’t just set up a family office ownership structure and think it won’t need some type of attention in the future. A number of factors, including regulatory changes, could compel you to revisit your ownership structure to ensure it still makes sense. See why it may b...

As noted in The New Family Office 5.0 Model, a rising number of family offices are allocating resources to direct investments, including building an in-house direct investment function to gain greater control, better diversification, increased flexibility, and income and estate tax benefits. From generating deal flow to due diligence, key cons...

For leaders of founder-owned companies, simply making the decision to sell or bring in an outside investor can be anxiety inducing. The transaction process itself is often filled with apprehensive moments—arguably none more so than the potential of sensitive information leaking. This primer helps business owners understand how to avoid leaks, how t...

While there are predictions of a recession amid a looming economic downturn, there are opportunities for investors to acquire distressed assets as part of their direct investing or mergers and acquisitions plan. In this 10-minute interview, attorney Tom Scannell highlights some of the issues potential buyers may face as they look at financially-dis...

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 investi...

For leaders of founder-owned businesses, raising significant capital without relinquishing control can seem challenging. But investors focused on non-control transactions are becoming more common. Non-control-oriented funds have boomed, fueling demand for minority recapitalizations and enabling business owners to maximize the valuation of their com...

While many family offices stay cognizant of continued volatility as investors, they also are continuing to search for the best investments in public and private markets. This report—based on 188 family office respondents from 32 countries—provides a comprehensive picture of how family offices view the world and the key factors driving their investm...

As a general counsel in the Family Office space, Nate Christensen speaks on the growth of direct investing by family offices, the competitive advantages and challenges for them, and advice for family office offices and those working with them. Nate also shares thoughts on how family offices are leveraging their own edge in direct investing. Hear mo...

There are both advantages and disadvantages for family offices considering a minority direct investment. In this interview with Brian Lucareli of Foley Private Client Services, Glenn Singleton spoke on the distinguishing characteristics of minority investments, key terms and their negotiations, common structures of minority investments, and techniq...