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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...

A dynamic portfolio can help address a number of investment challenges that families of wealth face, including varying multigenerational preferences, unique tax considerations, domicile requirements, and specific beneficiary needs. Yet there is also such a thing as overcomplexity, which can waste time, cause confusion, decrease potential returns, a...

The traditional 60/40 portfolio—a mix of 60% stocks and 40% bonds—is suffering through one of its worst periods in history. Although the demise of the 60/40 portfolio has been predicted before, investors may now face a new regime of high inflation and rising correlations between equities and fixed incomes. For investors in hard-hit 60/40 portfolios...

The expectations of an economic soft landing and favorable equity market in both 2023 and 2024 were possible due to the positive underpinnings of a healthy labor market, falling inflation, and a Fed pivot to rate cutting. In 2025, however, expectations are higher, policy shifts are underway, and several new factors that include tariffs, trade wars,...

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...

Typically, investors focus on more traditional asset classes, like stocks and bonds, where information is often readily available and digestible. Sometimes, however, sophisticated qualifying investors increase their capital allocations to private markets for reasons they believe are compelling enough to make it worth taking the risk. This primer wi...

Despite the hurdles and distinct challenges that come with adding private markets to an investment portfolio, many of the most sophisticated institutional investors are allocating to private markets. Historically, the asset class has generally outperformed public markets due to a range of factors, including the broader investment landscape, informa...

Amid evolving global dynamics, emerging market corporate debt offers ample and compelling investable opportunities. The diversity of the asset class gives investors a wide spectrum on which to effectuate their views and investment strategies. But investors should navigate with caution and take note of the five themes that will have a notable impact...