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...
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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...
Join host Damien Martin in his ongoing quest for insights and best practices for affluent families and their advisors as he sits down with guest Jeff Davidson to unpack the often mystifying and sometimes daunting world of the family office. Here’s what’s covered: Who is Jeff Davidson? @02:35 Developing a national family business succession pl...
For families with substantial diversified portfolio investments, costs are an important consideration when devising an overall wealth management strategy. While there are a range of cost estimates drawn from real world examples, each family’s wealth management cost formula is different when analyzing it through a framework and analysis of four part...
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...