Overview
In light of the favorable tax court ruling in Lender Management, LLC, v. Commissioner and the fact that miscellaneous itemized deductions (§212 deductions) are no longer deductible per the 2017 Tax Act, we are seeing a lot of interest in the profits interest structure. In this session, Tom Ward explored the pros, cons, and reasons why family offices use this structure, as well as the impact of tax reform on those who use it. We then heard from our very own member, Keith Lender, who shared a first-hand account with Allan Zachariah of their work on this important case and the best practices and lessons learned that may have applications for all FOX members considering or using the profits interest structure.
Date Published: Tuesday, March 6, 2018