Tax Law and International Tax Law

High-net-worth families are restructuring their family offices using the Lender model to qualify as separate trades or businesses for federal tax purposes. This strategic shift enables them to deduct investment-related expenses that were eliminated for individuals under the Tax Cuts and Jobs Act, creating significant tax efficiency opportunities through carefully designed management entities and allocation structures.

As public scrutiny and threats against corporate leaders intensify, more companies are investing in comprehensive security packages for senior executives.

Section 1202 of the US tax code offers qualified small business stock (QSBS) holders the ability to exclude significant capital gains from federal income tax, with recent legislation raising the exclusion cap to $15 million per taxpayer for stock acquired after July 4, 2025. Strategic use of properly structured non-grantor trusts can multiply these tax benefits through "trust stacking" while simultaneously achieving substantial estate tax savings. Cross-border families and multinational founders must coordi