Structuring a family office correctly is one of the most consequential and most frequently mishandled decisions in private wealth planning. Done right, it creates a tax-efficient, institutionally sound operating platform for everything the family does. Done wrong, it exposes the family to the permanent loss of deductibility of qualified trade or business expenses and a structure that cannot support the weight of the family’s financial complexity as it grows.

The Tax Cuts and Jobs Act of 2017 temporarily suspended miscellaneous itemized deductions under IRC §67(g) through 2025, eliminating the ability of high-net-worth families to deduct investment advisory fees, family office expenses, legal fees, tax preparation costs, and other costs of managing their wealth at the individual level. The One Big Beautiful Bill Act, signed into law on July 4, 2025, made that disallowance permanent. Families that historically relied on miscellaneous itemized deductions to offset the cost of managing significant wealth now face a permanent tax cost with no remedy under the traditional individual expense framework.

The Tax Court decisions in Lender v. Commissioner (2017) and Hellmann v. Commissioner (2018) opened a critical door. Where a family office can demonstrate that it operates as a bona fide trade or business under IRC §162, its expenses become fully deductible as ordinary and necessary business expenses rather than permanently disallowed miscellaneous itemized deductions. These decisions established the operational, structural, and staffing conditions a family office must satisfy to sustain that treatment and they remain the governing framework for family office structuring today.

Prior to implementation, we model the projected tax and non-tax benefits of the Lender family office structure for each family, providing a clear and quantified picture of the potential deductibility, long-term tax savings, and broader structural advantages before any commitment is made. This analysis allows families to make informed, confident decisions about whether and how to proceed.

Structuring & Implementation

• Feasibility analysis under Lender and Hellmann factors: services, client structure, staffing, compensation, and operations
• Design of management and investment entities, including fee structures and profits interests
• Expense allocation methodologies and supporting documentation frameworks

Governance & Documentation

• Investment management agreements, operating agreements, and oversight structures
• Multi-branch service models aligned with Lender’s multiple-client framework

Compliance & Ongoing Advisory

• Partnership and entity tax compliance (Form 1120; Form 1065; Schedule K-1)
• Profits interest allocation calculations and review
• Ongoing monitoring of trade or business qualification under §162
• Personal holding company analysis under IRC §541 and §543
• Advisory on liquidity events, asset dispositions, trust funding, and philanthropic integration

We provide federal and state income tax compliance and planning for ultra-high-net-worth individuals whose financial lives span numerous entities, extensive portfolios of pass-through interests, and some of the most complex and exotic transactional structures in private wealth. This is not high-volume individual tax work. It is highly specialized counsel for individuals whose returns demand the same institutional rigor as the family offices and enterprises they sit atop.

Our individual tax practice is built for complexity at scale, serving clients whose K-1 portfolios span an extensive portfolio of partnerships, private equity funds, hedge funds, and operating entities across multiple jurisdictions. We manage the full compliance picture: reconciling Schedule K-1s across layered partnership structures, tracking basis through tiered entity arrangements, modeling the interplay between passive and non-passive income, and coordinating the individual return with the broader entity and trust landscape.

• Charitable planning under IRC §170, including cash and non-cash contributions across private foundations, public charities, and donor-advised funds
• Tax treatment of private equity, hedge fund, venture capital, and cross-border fund interests, including PFIC analysis and foreign tax credit planning
• Oil and gas interests, including depletion, intangible drilling costs, and working interest considerations under IRC §613A
• Carried interest and applicable partnership interest planning under IRC §1061, including disposition and holding period analysis
• Qualified Small Business Stock planning under IRC §1202, including exclusion stacking and coordination across trusts and entities
• Passive activity, material participation, and grouping elections under IRC §469, with particular focus on recharacterization and rental real estate treatment
• Net Investment Income Tax planning and surtax exposure modeling under IRC §1411
• Alternative Minimum Tax exposure analysis and planning under IRC §55
• State residency, domicile, and source income planning across multiple jurisdictions, including audit defense positioning
• Liquidity event tax modeling, installment sale planning, and long-term cash-flow optimization
• Basis tracking and planning across an extensive portfolio of partnership interests, including IRC §743(b) adjustments and tiered entity structures
• Coordination of the individual return with trust, entity, and family office tax positions to ensure full alignment across the complete tax picture

We provide federal and state income tax compliance and planning for the full spectrum of trust structures (grantor, non-grantor, complex, simple, revocable, and irrevocable), including trusts holding extensive portfolios of K-1 interests, alternative investments, and operating assets. Our experience spans some of the largest and most complex trust structures in private wealth, and we bring that same level of rigor and attention to every client engagement.

On the estate and gift side, our practice is focused exclusively on advisory, by design. We bring extensive experience advising multi-generational families on wealth transfer strategy at the highest levels of complexity, having worked on planning for some of the largest private estates in the country. Rather than assume compliance liability, we function as a specialized strategic resource: working alongside estate planning attorneys and fiduciaries to design, pressure-test, and refine transfer tax strategies before they are executed.

Trust Tax Compliance & Planning

• Federal and state fiduciary income tax compliance across grantor, complex, simple, and irrevocable trusts
• Distributable Net Income (DNI) calculations, allocations, and fiduciary accounting income determinations
• Trust-level K-1 reporting across extensive portfolios of partnership, private equity, and alternative investment interests
• Basis tracking and IRC §643 planning across layered trust and entity structures
• Coordination of trust tax positions with individual, entity, and family office returns
• Passive activity and material participation analysis at the trust level under IRC §469
• Net Investment Income Tax planning for trusts and estates under IRC §1411
• State-level fiduciary income tax compliance and multi-jurisdictional trust situs planning

Estate & Gift Tax Advisory

• Strategic counsel on wealth transfer planning for high-net-worth and ultra-high-net-worth families
• Design and review of GRATs, SLATs, IDGTs, CLATs, and other transfer tax vehicles
• Valuation discount strategies, defined value clauses, and intra-family transfer structuring
• Generation-skipping transfer tax planning and dynasty trust strategy
• Annual exclusion and lifetime exemption optimization across family members and entities
• Coordination with estate planning counsel on pre-transaction planning and liquidity event preparation
• IRC §2036, §2038, and §2704 risk analysis on existing and proposed structures

Succession Architecture

• Generational governance frameworks and family constitutions
• Succession planning for family enterprises and operating businesses
• Integration of trusts, family offices, FLPs, and philanthropic vehicles into cohesive transfer strategies
• Liquidity planning for estate settlement and long-term capital needs
• Intra-family lending, defined value techniques, and installment sale strategies

Family limited partnerships and investment partnerships represent two of the most consequential and technically demanding structures in family wealth planning. When properly designed and administered, they serve as the connective tissue between a family’s operating businesses, investment assets, trust structures, and philanthropic vehicles, enabling coordinated governance, income allocation, and intergenerational transfer at scale.

The legal landscape governing these structures is shaped by decades of Tax Court litigation. The IRS has aggressively challenged FLPs lacking economic substance, bona fide business purpose, or proper formation and operation, making technical precision and ongoing compliance non-negotiable. Key decisions including Strangi v. Commissioner (2003), Kimbell v. United States (4th Cir. 2004), Estate of Bongard v. Commissioner (2005), and Estate of Holman v. Commissioner (2010) have collectively defined the conditions under which partnership structures withstand IRS scrutiny on valuation, transfer tax, and substance grounds.

Partnership Taxation & Allocations

• Income, gain, loss, and deduction allocations under IRC §704(b) and the substantial economic effect regulations
• Special allocations, guaranteed payments, and preferred return structures under IRC §707
• Capital account maintenance, targeted allocation methodologies, and book-tax disparities
• Disguised sale analysis under IRC §707(a)(2)(B) and related regulations
• At-risk limitation planning under IRC §465 and passive activity coordination under IRC §469
• Basis tracking, inside/outside basis disparities, and IRC §754 election planning
• IRC §743(b) and §734(b) adjustments upon transfers and distributions
• IRC §704(c) Built-in gain and loss method selection, tracking and allocations
• IRC §704(c)(1)(B) Mixing Bowl Rules

Structure, Governance & Integration

• Entity formation, operating agreements, and capital segmentation across asset classes
• Bona fide business purpose documentation and ongoing operational compliance
• Integration with grantor trusts, dynasty trusts, SLATs, and family office management entities
• Investment partnership structures for pooled family capital, co-investment vehicles, and carried interest arrangements
• Coordination of K-1 reporting, Schedule K-2/K-3 obligations, and partner-level tax planning

Philanthropy, at its most effective, is structured. We advise private foundations and philanthropically-minded families on formation, tax compliance, and the long-term stewardship of their charitable mission, integrated seamlessly with broader income, gift, and estate tax strategy.

• Formation and operational tax compliance
• Excise tax requirements and minimum distribution planning
• Integration with income, gift, and estate tax strategy
• Multigenerational governance and mission continuity
• Coordination with donor-advised funds, supporting organizations, and charitable remainder structures