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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...

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...

Seasoned investors know that you cannot predict the future of the markets. But smart private wealth managers know that the key to preserving and growing wealth is to anticipate critical trends that are likely to have a lasting impact. Where trends are concerned, 2024 has a lot brewing around the geopolitical conflicts, the explosion of artificial i...

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...

As traditional oil and gas companies face a range of challenges, including the emergence of alternative and renewable technologies, investors must find new ways to navigate the energy transition. For large-scale investors like endowments and foundations, investing in energy is both a challenge and an opportunity that demands a whole new approach.