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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...

Creating portfolios that are customized to a family’s unique investment goals and risk tolerance requires ingenuity and flexible thinking. However, the execution of risk management should be more systematic. Ultimately, the effective investors employ a risk management framework that accounts for potential risk at every stage of the investment proce...

On the rise is Americans’ interest in living outside the U.S. for an extended period or even indefinitely. There are many different reasons for wanting to move to new countries, including career prospects, favorable financial conditions, love and family, and often simply for la dolce vita. Whatever the reason, a thoughtful and holistic approac...

For most of the period from the Global Financial Crisis in 2008 through the end of the COVID pandemic in 2022, the Federal Reserve held interest rates near zero. As post-pandemic inflation surged in early 2022, the Federal Reserve began a rapid rate-hike cycle that ended in July 2023 with the Federal Funds Rate at 5.25% - 5.50%. As noted in this In...

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...

We are in a period of extraordinary wealth creation and accumulation that is driving the need for more family offices and expanding the breadth and depth of services that support the important work and collective well-being of the family. It's about the sustainability of the family office and preparing it for the long run. With the future of the fa...

After the Silicon Valley Bank (SVB) collapse marked another bank failure, it triggered questions regarding the various considerations and options for holding short-term funds. With this reference chart, see the comparisons that show the characteristics of demand deposits with government securities and various money market funds as cash managem...