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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...

We are pleased to announce that the 2016 FOX Value Price Study: The Critical Link in Ultra-Wealth Market is available for FOX members. Key Insights found in this study include: Advisors have lost at least some pricing power with prospects as fees quoted to prospective clients have dropped 17% since 2008 and 15% since 201...

The 2016-17 FOX Thought Leaders Council Report: Strengthening the Partnership Between Families and Advisors is a great resource for those who are seeking ways to construct sustainable partnerships and how to make them productive. Inside, you’ll find why partnerships are key to successful family/advisor relationships, what makes partnerships endurin...

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,...

The ultra-wealth business continues to perform well, but not without some growing pains. While advisors to families of wealth benefited from a strong rebound in the markets during 2020, for some firms costs are rising faster than revenue. Now that we are in the midst of a receding pandemic, what does this look back on 2020 tell us about how prepare...

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...

While 2024 saw global asset prices reach record highs, family office investors may benefit from reassessing both their expectations and how their investable assets are positioned for the future. We explore the possibility of a shifting investment landscape and why the years ahead may present a more challenging backdrop for sustaining and growing we...