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Publications
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08.01.2023Prepare to Comply With Upcoming Corporate Transparency Act Reporting RulesArticlesDomingo Such and Jamie Schafer wrote an article published in Trust & Estates titled "Prepare to Comply With Upcoming Corporate Transparency Act Reporting Rules" about the implications family offices and their advisors should be aware of regarding new reporting rules stemming from the Corporate Transparency Act.
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12.2020IRS Enforcement Aimed at High-Net-Worth TaxpayersArticlesAs high-net-worth taxpayers learn of recent Internal Revenue Service pronouncements, they’re rightfully asking their trusted advisors, “Could the IRS Wealth Squad be coming for me?”
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08.12.2020How to Prepare High-Net-Worth Clients for IRS Wealth Squad AuditsArticlesAt a recent conference, top officials with the Internal Revenue Service announced a renewed audit focus on high-net-worth (HNW) individuals and their related entities going forward.
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09.16.2019US Supreme Court Finds in Favor of Taxpayer Trust Beneficiary in KaestnerUpdatesOn June 21, 2019, the U.S. Supreme Court issued its opinion in North Carolina Department of Revenue v. Kimberly Rice Kaestner 1992 Family Trust. This unanimous decision stated that the State of North Carolina may not tax trust income that has not been distributed to the beneficiaries, for which the beneficiaries lack the right to demand the income, and for which the receipt of that income is uncertain simply because those beneficiaries reside in the state.
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03.14.2019Choice of Entity: Analyzing the Decision in the Wake of the New Tax ActArticles
The 2017 Tax Cuts and Jobs Act, coupled with the recent taxpayer victory in Lender Management, LLC v. Commissioner, has made family office planning a major focus of 2018. This article provides a general overview of family offices and their use in planning for the deductibility of investment management expenses before offering some considerations regarding the proper organizational structure for family office entities and family investment funds.
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04.26.2018Deductibility of Trust Expenses Under the Tax Cuts and Jobs ActArticles
Trusts & Estates
The Tax Cuts and Job Act of 2017 (the Act), was signed into law on Dec. 22, 2017, bringing a myriad of changes to the Internal Revenue Code and sparking a substantial amount of commentary and analysis. While much attention has been centered on the consequences of the Act for individual and business taxpayers, relatively little focus has been given to the impact of the Act on trust and estates. -
02.09.2018Private Company Tax Planning Opportunities for 2018UpdatesThe Tax Cuts and Jobs Act of 2017 and the recent taxpayer victory in the U.S. Tax Court’s Lender Management, LLC decision have created important planning opportunities for both our closely held and family-controlled entities in 2018.
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01.17.20182018 Key Trust & Estate Planning and Corporate Ownership Implications of the New Tax LawUpdates
With the passage of the Tax Cuts and Jobs Act of 2017, attorneys in Perkins Coie’s Trust & Estate Planning practice, along with our clients running closely held businesses, have already begun reviewing and implementing tax-efficient strategies.
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01.11.2018A New Era of Spousal Trust Planning: An Old Concern Arises with Reciprocal TrustsArticles
Bloomberg BNA: Tax and Accounting
With the Great Recession still fresh in the nation's collective memory and its wealth still seemingly in flux, and as the lifetime gift tax exemption shot up from $1 million to $5 million in 2011 and continued to rise (despite the threat of a return to $1 million after 2012), many individuals who were in a position to take advantage of the increase were hesitant to part with a significant amount, fearful that they could give away assets they may later need. -
02.2017 / 01.25.2017Avoid Ethical Pitfalls When Representing Family OfficesArticles
WealthManagement.com
Family offices continue to multiply, and the number of industry professionals who provide services to them continues to grow. The genesis of family offices dates back hundreds of years; wealth management and the deployment of capital in its various forms have evolved with family offices to recognize financial, human, intellectual and spiritual capital management. -
Winter 2016Understanding the Regulations Affecting the Deductibility of Investment Advisory Expenses by Individuals, Estates and Non-Grantor TrustsArticles
ABA Real Property, Trust and Estate Law Journal
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Spring 2016Fidelity-Philadelphia Trust Co. v. Smith: Form Over Substance?Articles
ACTEC Law Journal
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03.18.2016Deductibility of Investment Advisory Expenses: Impact of LimitationsArticles
Trusts & Estates
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03.08.2016Deductibility of Investment Advisory Expenses: Allocating “Unbundled” FeesArticles
Trusts & Estates
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02.29.2016Deductibility of Investment Advisory Expenses: Estates and Non-Grantor TrustsArticles
Trusts & Estates
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02.22.2016
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2016Best Practices: Leveraging Recent Updates in Federal Tax and State Trust Law to Transfer Wealth and Update Outdated Trust Provisions
Chapter
Inside The Minds, Best Practices For Structuring Trusts and EstatesLeading Lawyers on Drafting A Flexible Plan, Protecting The Client's Assets, and Leveraging Tax Strategies -
02.2014Innovative ESOP Transaction StructuresArticles
The National Center for Employee Ownership (NCEO) Issue Brief
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01.11.2013Guest Article: IRS Tax Authority Continues Pursuit of HNW Individuals and Family OfficesArticles
Wealth Briefing
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07.17.2012Is the Favorable Estate Planning Environment Ending?Articles
Financial Advisor
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2010Deductibility of Investment Advisory Expenses by Individuals, Estate and Non-Grantor TrustsArticles
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12.2010Relief for Failure to File Written Representations with the IRS for Split-Dollar LoansArticles
On the Subject
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2010'Tune Up' Your Estate Plan in Anticipation of Sweeping Changes to Estate TaxesArticles
Insights
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06.2009Avoid the Pitfalls of Trust PlanningArticlesThe Family Business Succession Handbook
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05.2009 / 06.2009An Estate Planning Tune-UpArticlesPrivate Wealth
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01.08.2009Changes to Federal and State Estate Taxes Warrant Estate Plan ReviewArticlesOn the Subject
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02.2007The Incomplete Equity Strategy May Bolster Sales to Grantor TrustsArticlesEstate Planning
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2007New Reporting Rule for Sales to Grantor TrustsArticles
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2005 / 04.2006Fix-Ups of Estate Plans After They Have Become Irrevocable (With Sample Language) (Part 2)ArticlesALI-ABA The Audio Estate Planner; ALI-ABA Estate Planning Course Materials Journal
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2005 / 02.2006Fix-Ups of Estate Plans After They Have Become Irrevocable (With Sample Language) (Part 1)"ArticlesALI-ABA The Audio Estate Planner; ALI-ABA Estate Planning Course Materials Journal
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08.2004Capital Trust Investment Accounts: CapTIAsArticles
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07.20.2004Restricted Management AccountsArticlesSteve Leimberg’s Estate Planning Newsletter
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06.2004 / 08.2004Just When You Thought It Was Over…Understanding the Demand Loan Trap: The Interaction of Section 2042 and the Final Split-Dollar RegulationsArticlesCCH Incorporated Journal of Retirement Planning
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09.2003State Estate Tax Law Changes Provide New Challenges, OpportunitiesArticlesOn the Subject
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12.2002 / 04.2003Applying Valuation Strategies to IRAsArticlesDistribution Advisor
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12.2001Qualified State Tuition Programs Under IRC 529: One of the Best Ways to Save for CollegeArticlesTrusts & Estates
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1999 - 2002A Common English Guide to Estate Planning Tools: Part IV The Sophisticated CourseArticlesFFI Practice Papers
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1999 - 2002A Common English Guide to Estate Planning Tools: Part III The Sophisticated Basic CourseArticlesFFI Practice Papers
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1999 - 2002A Common English Guide to Estate Planning Tools: Part II A Trust May Not Connote TrustArticlesFFI Practice Papers
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1999 - 2002A Common English Guide to Estate Planning Tools: Part I The Basic BasicsArticlesFFI Practice Papers
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09.1999Review of "The Intermingling of Business and Family Finances in Family-Owned Business"ArticlesFBR Commentaries
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04.1999Annual Exclusion Giving: Nonmarital Spousal Gift TrustsArticlesTrusts & Estates
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1999Family Business: Strategies for the New MillenniumArticlesFFI Conference Proceedings
Presentations
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01.24.2024Recent Tax DevelopmentsSpeaking EngagementsFOX Family Forum / Virtual
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11.07.2023Family Office – Domestic and AbroadSpeaking Engagements60th Annual Hawaii Tax Institute / Honolulu, HI
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10.19.2023Jurisdictional Planning for Family OfficesSpeaking EngagementsFall Forum
Family Wealth Alliance / Chicago, IL -
01.24.2023State Selection and the Chartered vs. Uncharted DecisionSpeaking EngagementsFamily Office Exchange PTC Workshop / Webinar
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11.11.2022Using Non-grantor Trusts: Assessing Income Tax Benefits and Issues Related to Assignment of Income, State Income Taxes, Salt Deductions and Installment SalesSpeaking Engagements
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11.08.2022Tax Considerations of Converting Grantor Trusts to Nongrantor TrustsSpeaking Engagements59th Annual Hawaii Tax Institute / Honolulu, HI
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11.03.2022Wealth Transfer Strategies: Changes and OpportunitiesSpeaking EngagementsPanelist
Wealth Alliance Fall Forum / Chicago, IL -
03.01.2022Primer on Working with High-Net-Worth Family and Family OfficesSpeaking Engagements
Panelist
Trusts & Estates Forums / Webinar -
02.16.2022Transforming the PTC Idea into an Operating Trust CompanySpeaking EngagementsFamily Office Exchange Private Trust Company Fundamentals Workshop / Webinar
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11.03.2021Wealth Transfer Strategies: Changes and OpportunitiesSpeaking EngagementsThe Family Wealth Alliance 2021 Fall Forum / Chicago, ILWith a push by the Biden Administration to return federal estate taxes to their historic norms, clients are laser-focused on their estate plans and are turning to their advisors for guidance.
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10.06.2021Family Office Regulatory MayhemSpeaking Engagements
Executive Council ’14 Meeting
Family Office Council / Webinar -
06.02.2021IRS HNW Audit Program ImpactsSpeaking EngagementsPanelist
The UHNW Institute / Webinar -
04.29.2021How to Deal with the IRS Wealth SquadSpeaking EngagementsPanelist
Trusts & Estates Magazine / Webinar -
04.21.2021Family Co-Investment Entities in a Post-Powell/Cahill WorldSpeaking EngagementsChicago Estate Planning Council /Webinar
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01.28.2021PTC Evolution: Risks and Opportunities—a Panel with State Commissioner, PTC Administrator, PTC Exec and Legal ExpertSpeaking EngagementsPanelist
Family Office Exchange PTC Workshop / Webinar -
01.26.2021A New Era of Spousal Trust Planning: An Old Concern Arises with Reciprocal TrustsSpeaking EngagementsABA Section of Taxation Midyear Meeting / Webinar
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12.07.2020Advanced Topics in Discretionary Distributions Advanced SchoolSpeaking EngagementsABA Wealth and Trust Schools / Webinar
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10.20.2020Planning/Pitfalls with SLATsSpeaking EngagementsGreater Boca Raton Estate Planning Council / Webinar
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06.18.2020Planning Pitfalls with SLATsSpeaking Engagements
Estate Counselor’s Forum / Webinar
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06.02.2020The Use of Grantor Trusts in Today’s PlanningSpeaking EngagementsPanelist Discussion
Baker Tilly Estate and Trust Conference / Webinar -
04.22.2020Protecting Fiduciary Integrity by Minimizing Litigation Risk in Both New and Existing ESOP TransactionsSpeaking EngagementsNCEO 2020 Employee Ownership Conference / Webinar
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01.29.2020Can You Have Your Cake and Eat It Too: Gift/Estate Tax and Basis Planning Under the 2017 Tax ActSpeaking EngagementsUSC 2020 Tax Institute / Los Angeles, CA
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11.05.2019
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10.17.2019Analyzing the Decision in the Wake of the 2017 Tax ActSpeaking Engagements2019 Fall Forum hosted by South Dakota Trust Association / Sioux Falls, SD
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07.17.2019Analyzing the Decision in the Wake of the 2017 Tax ActSpeaking EngagementsFOX Family Office Forum / Chicago, IL
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04.30.2019Choice of Entity - Analyzing the Decision in the Wake of the New Tax ActSpeaking EngagementsCIO Wealth Strategy Roundtable/WPS Education Series hosted by U.S. Trust / Chicago, IL
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10.18.2018Tax and Legal Structuring of the Family OfficeSpeaking Engagements
Abbot Downing Family Forum / Chicago, IL
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07.31.2018Reciprocal Trusts - Issues and ConcernsSpeaking EngagementsPlanning for High Net Worth Clients Symposium / Chicago, IL
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07.18.2018Considerations for Converting Business StructuresSpeaking EngagementsFOX Family Office Forum / Chicago, IL
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06.07.2018The Modern AdvisorSpeaking EngagementsWealth Advisor and Wealth Planner “Tag” Summit - Trust Advise Grow” hosted by The Northern Trust Company / Chicago, IL
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05.16.2018Life Insurance as a Funding Vehicle for Multi-Generational Wealth Transfer and Gift/Valuation IssuesSpeaking Engagements2018 Chicago Estate Planning Conference / Chicago, IL
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04.24.2018Ownership, Succession, Transfer Tax and Other ConsiderationsSpeaking EngagementsFOX Profits Interest Planning meeting / Chicago, IL
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03.15.2018 & 03.20.2018Tax Cuts and Jobs Act: What Clients Need to Know and DoSpeaking Engagements
2018 FOX Executive Council ’04 Meeting / Boca Raton, FL
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02.22.2018Governing the PFTC: Owners and DirectorsSpeaking Engagements2018 FOX Private Family Trust Company Workshop / Fort Lauderdale, FL
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11.15.2017Framework for Tax ReformSpeaking Engagements
Philadelphia Family Office Group / Philadelphia, PA
Panel Discussion -
11.07.2017Pre-Immigration Tax Planning (for NRAs Moving to the US to Become US Persons)Speaking Engagements54th Annual Hawaii Tax Institute / Honolulu, HI
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10.26.2017Reciprocal Trusts: Language That Causes Problems And Reciprocal ConsiderationSpeaking Engagements43rd Annual Notre Dame Tax & Estate Planning Institute / South Bend, IN
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10.19.2017Remaking Income Tax and Wealth Transfer StrategiesSpeaking Engagements2017 Alliance Fall Forum / Chicago, IL
Panel Discussion -
10.09.2017Chicago Estate Planning Council Diversity Committee: Student OutreachSpeaking EngagementsChicago, IL
Panel Discussion -
09.29.2017Building Resiliency in Family and BusinessSpeaking EngagementsFamily Business Network / New York, NY
Panel Discussion -
09.24.2017Advanced Topics in Discretionary DistributionsSpeaking EngagementsAmerican Bankers Association’s National Graduate Trust Schools / Atlanta, GA
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09.16.2017Investment Advisory Expenses: Minimizing Impact of the New Rules and Maximizing DeductionsSpeaking EngagementsSTEP WY 2017 International Estate Planning Conference / Jackson, Hole, WY
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02.14.2017‘til Death Do Us Part: Understanding the Prenup ProcessSpeaking EngagementsFBN North America / Webinar
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12.01.2016Annual High Net Worth and Family Worth ConferenceSpeaking EngagementsCFA Society Philadelphia / Philadelphia, PA
Panel Discussion -
11.08.2016Maximize Your Clients’ Itemized Deductions: Applying The IRC Section 67(E) Miscellaneous Itemized Deductions Rules to Individuals, Estates, Trusts and Family OfficesSpeaking Engagements53rd Annual Hawaii Tax Institute / Honolulu, HI
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09.25.2016Advanced Topics in Discretionary DistributionsSpeaking EngagementsAmerican Bankers Association’s National Graduate Trust Schools / Atlanta, GA
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09.07.2016The Proposed Section 2704 Regulations Is the Window Closing on Lack of Control Discounts in the Family Controlled Entity?Speaking EngagementsUrgent FOX Webinar - Is the Clock Ticking for Valuation Discounts? / Chicago, IL
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05.18.2016 & 05.26.2016The Possibilities and Potential Pitfalls of Premium FinanceSpeaking EngagementsIICLE Short Course / Champaign, IL
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04.27.2016Portability Today: Making It Work for ClientsSpeaking EngagementsALI-CLE Webinar
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02.23.2016The Possibilities and Potential Pitfalls of Premium FinanceSpeaking Engagements2016 National Advisor Advisors Conference / Streamsong, FL
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02.10.2016Burdens and Solutions for Operating a PFTC Distant from HomeSpeaking EngagementsFamily Office Exchange: Private Family Trust Company Workshop and Symposium / Miami Beach, FL
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12.03.2015Annual High Net Worth and Family Wealth ConferenceSpeaking EngagementsCFA Society Philadelphia / Philadelphia, PA
Panel Discussion -
09.27.2015Advanced Topics in Discretionary DistributionsSpeaking EngagementsAmerican Bankers Association’s National Graduate Trust Schools / Atlanta, GA
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09.18.2015The 2% Floor - What Every Estate Planner Needs to Know About IRC Section 67(E)Speaking Engagements2015 Annual Advanced Estate Planning Conference / Sun Valley, ID
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08.27.2015Recent DevelopmentsSpeaking EngagementsNorthern Trust / Chicago, IL
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08.12.2015Regulatory Challenges For the PFTC in the FATCA/FINRA EraSpeaking EngagementsFamily Office Exchange Webinar
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07.29.2015Final IRS Sect. 67(E) Regulations For Estate and Trust TaxpayersSpeaking EngagementsClear Law Institute Webinar
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12.04.2014Taxes, Taxes: What Can We Do About Taxes?Speaking EngagementsCFA Society Philadelphia –High Net Worth and Family Wealth Conference / Philadelphia, PA
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11.19.2014Planning for Spouses and Beneficiaries: Best Practices Under ATRA, DOMA, and HillmanSpeaking EngagementsALI-CLE Webinar
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10.15.2014Final IRS Sect. 67(e) Regs for Estate and Trust Taxpayers: Applying the Required 2% Deduction FloorSpeaking EngagementsStafford Webinar
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09.17.2014Chicago Estate Planning Diversity Committee InitiativeSpeaking EngagementsLoyola University / Chicago, IL
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08.12.2014Advance Estate PlanningSpeaking EngagementsFamily Business Stewardship Institute / Chicago, IL
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06.06.2014Is the World Really Flat for U.S. Families Investing Abroad?Speaking EngagementsSustainable Family Office Operations and Management Conference / New York, NY
Panel Discussion -
12.05.2013Estate and Wealth Planning in the Wake of 2012 LegislationSpeaking EngagementsCFA Society Philadelphia – Annual High Net Worth Conference / Philadelphia, PA
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03.17.2005Planning for Executive & High Net Worth IndividualsSpeaking EngagementsQuad City Estate Planning Council / Bettendorf, IA
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02.05.2005Advanced Estate Planning TechniquesSpeaking EngagementsFollet Corporation / Chicago, IL
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01.20.2005Enhancing Wealth Transfer Strategies with Financial Instruments: A Panel DiscussionSpeaking EngagementsChicago Estate Planning Council / Chicago, IL
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11.05.2004Recent Developments and Planning Strategies for High Net Worth ClientsSpeaking EngagementsThe Capital Trust Company of Delaware Symposium Series / Washington, D.C.
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10.23.2004Restricted Management AccountsSpeaking EngagementsWealth Counsel Study Group / Chicago, IL
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10.07.2004Asset Protection Strategies for Your ClientsSpeaking EngagementsThe 7th Annual Financial Advisor Symposium / Chicago, IL
