The U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued its highly anticipated final rule implementing the beneficial ownership information reporting requirements of the Corporate Transparency Act legislation on September 29, 2022.

Perkins Coie and Flourish announce the release of a white paper that highlights key regulatory and compliance considerations for RIAs looking to engage with cryptocurrencies.

As 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?”

At 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.

The Washington Department of Revenue (DOR) on May 28, 2020, published a Special Notice advising that, beginning June 1, 2020, in determining a decedent’s taxable estate for Washington estate tax purposes, the DOR will treat a business entity holding real property as an intangible asset regardless of whether the business entity served a true business purpose.

Between March 17 and April 9, 2020, the U.S. Department of Treasury and the IRS issued a series of notices automatically extending to July 15 the deadline for the filing of all federal income and gift tax returns and all federal estate tax returns due on or after April 1, payment of all federal income, gift, and generation-skipping transfer (GST) tax in respect of the 2019 taxable year, and payment of all federal estate tax and estimated federal income tax for the 2020 taxable year otherwise due on or after April 1, 2020, and before July 15, 2020.

An important improvement aimed at ensuring a faster, less expensive, and more tailored approach to reorganizations involving smaller businesses was embedded in the recent $2 trillion recovery package known as the Coronavirus Aid, Relief and Economic Security Act (CARES Act).

Employers are rightfully concerned about what, if anything, they should be doing to respond to the continued spread of the coronavirus (COVID-19), with confirmed cases in dozens of countries, including the United States.

On 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.

Over the past month, the Internal Revenue Service (IRS) has sent letters to over ten thousand taxpayers that it believes may have failed to report virtual currency transactions (primarily Bitcoin-related) or may have omitted income derived from virtual currency transactions.

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.

What is ‘custody’ and how does it relate to fiduciaries? ‘Custody’ is defined in different ways, depending on its purpose. At its core, custody relates to an arrangement under which an asset is recognised as being owned, or otherwise possessed by a person, on the person’s own behalf or on behalf of another.

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.

The IRS recently announced that it would end the Offshore Voluntary Disclosure Program (OVDP).

The 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.

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. 

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.

Last week, the Tax Cut and Jobs Act was signed into law and generally takes effect on January 1, 2018. In this update, we summarize some of the most significant tax law changes and suggest steps you might consider taking before the end of 2017 to reduce your income tax liability.

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.

The election of Donald Trump and Republican majorities in U.S. Congress make the future of the federal transfer tax system (gift, estate and generation-skipping transfer (GST) taxes) uncertain. President-elect Trump and congressional Republicans may seek to repeal or significantly modify those taxes. They have also called for significant income tax reform. These changes would impact personal and family estate planning as well as family offices, businesses and investment companies.

The federal government proposed sweeping new tax rules earlier this month that would dramatically affect family businesses, investment partnerships and other entities.

Family office key employees have new flexibility under recent SEC guidance regarding the nature and range of persons who can properly be involved in the administration of their trusts.

Family offices have existed for over a century and have been formed to implement very important, complex objectives, including investment management, corporate succession, estate, gift, and income tax planning and charitable giving.

Family offices have existed for over a century and have been formed to implement very important and complex objectives, including investment management, corporate succession, estate, gift and income tax planning, and charitable giving issues that are important to the members of the family.

Welcome to the Family Office Services Group's new update series "Did You Know?"  It is an easy-to-read, timely and brief focus on legal issues and developments facing you and Family Offices throughout the year.  In our first edition of "Did You Know?" we look ahead to the end of the year and the many tax concerns that can arise as the calendar year closes.

Just as the end of the year can be a good time to make charitable donations, it can also be a good time to make political contributions for those who give frequently in federal elections.  The federal campaign finance laws cap the total amount that an individual may give to all federal candidates and committees combined during a two-year period.

The Patient Protection and Affordable Care Act of 2010 (Affordable Care Act) institutes a new 3.8 percent Medicare surtax on net investment income effective January 1, 2013.

2012 may be the ideal year for Washington residents to make gifts.  The combination of the current Washington State tax laws and the change in the federal transfer tax structure presents a unique opportunity for residents to make large gifts to reduce the impact of the State estate tax.

As indicated in a prior update, on June 22, 2011, the SEC adopted a rule (Rule) defining the term "family office" for purposes of identifying entities eligible for exclusion from registration as an investment adviser under the Investment Advisers Act of 1940 (Advisers Act).  In connection therewith, the staff of the Division of Investment Management (Staff) recently provided responses to select questions regarding the definition of a "family office" under the Rule.  Highlighted below are (i) summaries of the Staff's responses to a few of the more pertinent questions, and (ii) a reminder with respect to a few provisions of the Rule which may cause the unsuspecting family office to inadvertently fall outside of the registration exclusion

At an open meeting of the Securities and Exchange Commission (SEC) on June 23, 2011, the SEC Commissioners approved a new rule defining “family offices.” Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) excluded family offices from the definition of investment adviser under the Investment Advisers Act of 1940 (Advisers Act) and thereby exempted family offices from the registration requirements under the Advisers Act, as amended by the Dodd-Frank Act. However, Section 409 of the Dodd-Frank Act also directed the SEC to adopt a rule defining the term “family office” in order to identify the entities eligible for the exclusion. On June 23, 2011, the SEC adopted such a rule.