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...
A high-quality board of directors with a range of talents and experience can be a powerful resource for your company. Taking steps to ensure your board is well-designed, well-informed, and properly engaged will reap significant benefits for your company’s shareholders and management team.
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...
Independent directors can enhance a family business board in a variety of ways, including providing expertise in a range of subject matter areas, leadership development, and learning opportunities. They can also help owners expand diverse viewpoints, adapt to changing circumstances in the market, and help make decisions that are difficult for the f...
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...