Evolution of the Lender Structure: Deduction of Investment Management Fees

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 that evolution, guidance is provided on implementing a Lender-Type structure through the use of a Private Trust Company.