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The SECURE 2.0 Act of 2022, signed into law by President Joe Biden on December 29, 2022, makes significant changes to the administration and taxation of retirement plans. It addresses many practical concerns that surfaced after the passage of the original SECURE Act in 2019 and during the pandemic. Some of the key changes, including the rules for s...

U.S. tax and information reporting obligations have become an increasing concern for international families and their succession planning structures. Missed or late filings can result in steep penalties, even when no tax is due. The Foreign Account Tax Compliance Act (FATCA) is alerting the Internal Revenue Service (IRS) to income and accounts held...

In this 10-minute interview, attorney Jordan Bergmann of Foley & Lardner joins Brian Lucareli to discuss qualified business stock (QSBS). During the interview, Jordan defined QSBS and the tax benefits they provide and how family offices can take advantage of the QSBS as part of their wealth management and tax planning strategy.

The issue of concentrated low-basis holdings is a challenge that has vexed wealth managers and their clients for decades. Put simply, if a large majority of your wealth is concentrated in a single position, should you sell some of it and move the proceeds to a more diversified portfolio of investments? However, the sale position oftentimes carries ...

The importance of meeting U.S. tax and reporting deadlines cannot be overstated. With the IRS continuing to strengthen its efforts to enforce compliance with initiatives specifically targeting foreign information reporting, this U.S. reporting checklist by Kozusko Harris Duncan can help family advisers and trustees of foreign trusts determine what ...

With the new administration in the U.S. and its focus on various parts of the Tax Cuts and Jobs Act (the TCJA) and the estate tax, changes are expected amid the balancing of competing considerations. In this 10-minute interview, Jason Kohout, partner and co-chair of the Family Offices group at Foley & Lardner, and John Strom, federal lobbyist a...

For many art collectors, the allure of acquiring and displaying art often overshadows the effort required to manage it properly and plan for its eventual disposition. After all, upon death, you can’t take it with you. Estate planning for art collectors involves navigating a complex landscape of valuation, tax, and management issues. Without a strat...

Effectively transitioning a business to the next generation of owners through a business succession plan that incorporates estate tax planning will result in the most value being retained by the owners and their families. Whether the business is entirely family owned or has unrelated owners, each scenario comes with its own complications but with c...

With an unprecedented $80 billion additional funding allocated for the Internal Revenue Service (IRS), there will be an expected 3,700 new agents hired as part of ramping up audits of the largest and most complex partnership returns and other tax enforcement initiatives. There will also be more focus on high income individuals, foreign bank account...

The most popular forms of equity-based compensation are stock options and restricted stock. It is not uncommon for these vehicles to compose a substantial portion of an executive’s net worth. Accordingly, it is important that executives fully understand the income tax treatment of options and restricted stock in order to maximize the after-tax valu...

This article explains how Tax Advantaged Equity (TAE) portfolios are traded over time and illustrates how value is achieved over the course of the portfolio’s life. For a TAE portfolio with an objective to harvest available losses and minimize gains while managing risk, there will generally be a few major phases through the life of the portfolio, i...

As tax strategy becomes more central than ever to business success, tax leaders must adopt new capabilities beyond those traditionally required to lead the tax function. Essential to this evolution is the ability to develop and execute a forward-looking tax roadmap that fully integrates emerging technologies such as artificial intelligence (AI). ...

Individuals with substantial business holdings often face complicated estate tax issues. Failing to recognize and plan for these issues may adversely impact the ability of the estate to timely pay any estate tax it owes. What is more, a lack of planning can affect the ability of the business to continue operating in the manner envisioned by the cur...

Cryptocurrency has revolutionized the financial markets but also created tax traps for the unwary investor. Building on proposed regulations issued in 2023, the IRS has increased its oversight of cryptocurrency transactions by requiring brokers, beginning in 2025, to report investor sales and exchanges in connection with such transactions. Taxpayer...

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...