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Recently the IRS released proposed regulations under Chapter 14 of the Internal Revenue Code that would severely limit—if not eliminate—the application of valuation discounts, including lack of marketability and minority discounts, to interests in closely held family entities for gift, estate, and generation-skipping transfer tax purpos...

For years, owners of family-controlled companies have taken advantage of applicable valuation discounts to advance their objectives in transferring wealth and company ownership to future generations in a tax efficient manner. On August 2, the Treasury Department issued proposed regulations under Internal Revenue Code Section 2704 to curb the use of...

Avoiding the issue of succession planning is much easier than starting a conversation about handing over the reins to other family members. But avoidance does not defer the inevitable, and it puts family harmony and wealth at risk. As patriarchs and matriarchs of wealth families confront the issue of succession planning, there are seven questions f...

Poorly structured family meetings that lack a clear purpose and agenda can do more harm than good. Failing to get buy-in from all family members can cause irreparable damage to relationships, despite the best of intentions. There are five key tips for holding a successful family meeting, which is an essential ingredient for managing wealth across g...

At the start of a family enterprise journey, there is often a patriarch (or matriarch) who was both an entrepreneur and a leader who overcame uncertainty or adversity to create something very special with the potential to last for many generations. For the families seeking to sustain their legacies, there will come a time for the patriarchs to move...

The planning landscape is likely to change even more as families seek to provide a sustainable pool of wealth not only for succeeding generations but also for the current generation. Nease, Lagana, Eden & Culley Inc. highlights the most significant of these changes and some of the advantages they present for planners and clients who are prepared to...

Analysis by Spring Mountain Capital shows that increased spending will profoundly jeopardize the long-term health of endowments. This paper proposes a framework for analyzing spending decisions that can be of use to endowments and other types of investors who need to balance long-term growth objectives with short-term spending needs.

Experiencing an investment loss is bad enough, but that situation is even worse when those losses cannot be used to reduce tax liability. Rothstein Kass explores the recent Garnett decision by the U.S. Tax Court, which broadened the rules used to determine whether participation in a business activity can be considered passive activity. This designa...

The unified managed household, the most recent extension of overlay portfolio management, extends overlay management services to households with multiple accounts, multiple individuals and multiple custodians. This paper from Natixis explains the evolution of overlay management and describes the benefits of the unified managed household, particular...

Britain's new reduction of capital procedure provides a flexible and inexpensive way for family-owned businesses to restructure or return value to shareholders. This report from Withers provides practical examples of how the procedure can be used in paying dividends, demergers, share buy-backs as well as paying up unpaid amounts on shares and disso...

Why, when and how legal and financial advisors counsel their clients around their charitable giving options has important implications for the donor, for the gift planner, for charitable organizations and for society. The author makes a series of recommendations on how the advisor-client relationship can best be structured in the interests of both.

The article argues that special needs planning on behalf of a disabled child means assembling a team of professionals with complementary competences: estate planning attorney, a financial advisor, and an accountant, as well as the parents, siblings, social workers/case manager and, if feasible, the child in question. Personal, financial, and legal ...

This paper explores the tax-management strategy of realizing long-term capital gains in a portfolio of equities and quantify how much it can add to after-tax performance. This approach is counter to the more common strategy of deferring the realization of capital gains as long as possible while only realizing capital losses. It also evaluates the a...

The author, a 4th generation heir to the Carnation fortune, maps out a framework for effective long-term wealth management. The principles apply equally well whether you're managing a nest egg of $1 million or $1 billion. They apply regardless of time horizon and family complexity, and they apply whether your ambitions are aggressive or conservativ...

Research shows investment managers are far too willing to incur a large negative tax alpha for taxable clients while pursuing a pretax alpha. The result is that most investment management products offer a combined alpha that is negative: pretax alpha, whether good or bad, less a relentlessly negative tax alpha.