Family Office Tax Update: Structuring, Meeting Trade or Business Criteria, Recent and Impending Legislation

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A


Conducted on Wednesday, May 26, 2021

Recorded event now available

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Program Materials

This webinar will explain how recent and imminent tax changes impact family offices. Our panel of family wealth professionals will explore tax planning strategies to minimize taxes paid by these families and their offices.

Description

A family office manages investments for a wealthy family with a primary goal of increasing and transferring wealth across generations. Recent legislative changes and the current state of the economy have generated new planning opportunities for family offices. Offices operating as trade or businesses can salvage deductions lost under the 2017 Tax Act. Lender Management L.L.C., T.C. Memo. 2017-246 found that expenses were deductible as ordinary and necessary under IRC Section 162 if the office met trade or business criteria.

More recently, diverse and numerous legislative and regulatory tax changes have increased tax considerations for family offices. The CARES act temporarily suspended the adjusted gross income limitation for charitable contributions. The Service recently released regulations for GILTI high-tax income, and final regulations under Section 1061 were issued for carried interest.

In addition to these changes, family office advisers must also consider impending Biden administration tax changes. Tax advisers working with family offices need to grasp these changes to assist family offices in preserving and growing generational wealth.

Listen as our panel of family office experts discusses which clients are the best candidates for family offices, structuring family offices to maximize tax savings, and the impact of recent and impending legislation on these entities.

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Outline

  1. The family office
  2. Structuring considerations
  3. Compliance issues
  4. Recent legislative changes
  5. Potential upcoming tax changes
  6. Best practices

Benefits

The panel will review these and other critical issues:

  • When is granting a profit interest a taxable event?
  • What criteria must be met for a family office to be considered a trade or business?
  • How can family offices prepare for upcoming tax changes?
  • How are family offices impacted by the many recent legislative changes?
  • What entity and structuring options are the most appropriate for family offices?

Faculty

Becker, Joshua
Joshua M. R. Becker, J.D.

Attorney
Kramer Levin Naftalis & Frankel

Mr. Becker works on matters involving federal, state and local tax issues, in particular the tax aspects of mergers and...  |  Read More

Borden, Aaron
Aaron Borden, J.D., CPA

Managing Director
Grant Thornton

Mr. Borden has more than 15 years’ experience finding solutions to complex tax problems for his clients....  |  Read More

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