Family Office Tax Roundtable 2023

Nathan R. Brown focuses his practice on counseling individuals, families and business owners in the development and implementation of estate planning strategies designed to maximize and protect the transfer of wealth to future generations. Nathan also acts as a senior adviser and “general counsel” to many family offices, coordinating a wide array of legal services.

In addition to advising clients on tax planning strategies, Nathan works closely with multi-generational families to design and implement business succession plans and family governance structures (such as private trust companies and family offices).

Nathan speaks frequently across the country on many estate planning topics and has published articles in The Florida Tax Review, The Tax Lawyer, The Florida Bar Journal, Probate & Property Magazine (American Bar Association), Estates, Gifts and Trusts Journal (Tax Management) and Trust & Estates, Taxes - The Tax Magazine and Estate Planning. Nathan focuses many of his speeches and articles on family office and private trust company structuring and planning with carried interest for investment fund principals.

In law school, Nathan served as an extern for the Honorable Kermit V. Lipez of the First Circuit Court of Appeals.

Neil T. Kawashima is the head of the Firm’s Private Client Practice Group and has a diverse practice, representing wealthy individuals and families in matters related to philanthropy and assisting clients with estate and wealth transfer planning, business succession and governance, and estate and trust administration. Neil’s clients include philanthropists, owners of privately held businesses, beneficiaries of long-term trusts, fiduciaries and entrepreneurs.

A significant portion of Neil’s practice is focused on philanthropic matters. He counsels individuals and families on charitable giving strategies, helping them to create tax-exempt entities, including private foundations, operating foundations, public charities, supporting organizations and social welfare organizations.

Neil also has significant experience counseling his clients on the design and implementation of charitable gift and pledge agreements, split-interest charitable trusts and other charitable giving strategies. He advises clients on issues concerning donative intent, “mission drift,” long-term governance of philanthropic vehicles and charitable components of family offices and family investment structure.

On behalf of his clients, Neil has negotiated major gifts with charitable organizations and has helped his clients identify, formulate and enforce their charitable goals. Neil has significant experience advising clients on state and federal audits related to charitable organizations and charitable giving.

Neil frequently speaks and writes on matters involving philanthropy.

Patrick J. McCurry concentrates his practice on the corporate and tax aspects of complex business and investment transactions, with a particular focus on transactions involving single-family offices, private equity funds and other financial sponsors (on both buy and sell-side), emerging businesses, partnerships and strategic joint ventures, limited liability companies and closely held corporations.

Patrick has extensive experience in working with single-family offices in connection with the formation and/or restructuring of family offices and private trust companies, the creation of investment funds, the establishment of incentive equity programs for key employees and related income tax planning.  He also routinely works on complex tax planning for high-net-worth individual and families, tax structuring healthcare services transactions and tax controversy matters.

Patrick is Co-Leader of the Firm’s Closely Held and Passthroughs Affinity Group.

Ranked as “Band 1” by Chambers High Net Worth in its national Family Offices & Funds Restructuring category, clients praise Patrick for being “a lucid communicator, even of incredibly complex tax and legal concepts.” Other clients note that Patrick “brings a level of knowledge and expertise in family office and partnership taxation” and he “never brings up an issue without thinking about multiple potential solutions.”

While in law school, Patrick served as an extern for the Honorable Ronald A. Guzman, US District Court for the Northern District of Illinois. He also was a member of the Loyola University Chicago Law Journal.

Elise J. McGee advises high-net-worth individuals and business owners on all aspects of wealth-transfer planning, including estate and trust administration, leveraged wealth-transfer techniques, tax matters, cryptocurrency and QSBS planning, real estate transactions and closely held business matters. Elise has extensive experience working with owners of closely held businesses to develop governance and succession plans, and on corporate, tax and compliance matters relating to those businesses.

Elise specializes in the formation and operation of private trust companies, and has advised clients on these structures in multiple jurisdictions. Elise has worked with state regulators to develop customized private trust company structures for clients, including for international families. Most recently, she co-drafted Wyoming’s 2019 trust company legislation including 2021 legislative updates. Elise has analyzed SEC and regulatory compliance issues facing private trust companies, and has helped clients develop policies and procedures for their private trust companies. She also advises clients on the litigation and regulatory risks facing private trust companies and their decision-makers.

Elise works with clients, including registered investment advisers and multi-family offices, to establish and transition trusteeship to retail trust companies. She also advises retail trust companies on cryptocurrency custody matters. She helps clients structure the multi-jurisdictional relationships between trust companies, family offices and closely held businesses.

Elise speaks frequently on the subject of estate planning, state income tax strategies, digital assets and trust companies. She has lectured at the University of Wyoming College of Law and serves on the Executive Committee of the Chicago Bar Association Trust Law Committee.

While in law school, Elise was an executive editor for The Michigan Journal of Race & Law. Prior to law school, she worked as a senior research analyst for Lexecon, where she performed research and statistical analyses focusing on the application of economics to litigation.

Victoria (Tori) Pambianco Ose advises high-net-worth individuals and families on all aspects of wealth-transfer planning, including estate, gift and generation-skipping transfer tax matters, estate and trust administration, business succession and charitable giving techniques.

Tori has extensive experience designing customized estate plans for individuals and families and implementing complex wealth-transfer techniques. She also has significant experience advising clients on a variety of philanthropic issues, including the development of charitable giving strategies, structuring and negotiating large charitable gifts, and the formation and operation of charitable trusts and foundations. In addition, Tori has experience advising families with international ties and non-US business interests.

Tori regularly speaks to regional and national audiences on issues related to philanthropy and on a variety of other topics in estate planning.

Adam K. Sherman provides legal counsel on a wide range of wealth transfer, tax, estate planning and business succession matters for high-net-worth individuals and business owners.

Adam has extensive experience structuring and implementing sophisticated wealth transfer techniques and working with owners of closely held businesses to develop customized succession plans. Adam also advises clients on a range of issues relating to the formation and maintenance of family office and private trust company structures.

Adam counsels executors, trustees and beneficiaries in all aspects of estate and trust administration, including the preparation of federal estate tax returns and judicial and non-judicial trust accountings. He has also been involved in numerous estate and gift tax audit proceedings before the Internal Revenue Service (IRS) and has successfully obtained favorable private letter rulings for his clients on a range of income and transfer tax issues.

On international matters, Adam has advised multinational families on compliance with the Foreign Account Tax Compliance Act (FATCA) and counseled US-based clients participating in the IRS's Offshore Voluntary Disclosure Program (OVDP).

Adam has spoken extensively on estate planning topics, including wealth transfer planning, gift, estate and generation-skipping transfer (GST) tax reporting, and exercising powers of appointment.

While in law school, Adam was a staff member of the Chicago Journal of International Law, in which he has his note (on the international legal status of drone operators) published in 2004.

Todd A. Solomon focuses his practice on designing, amending and administering pension, profit sharing, 401(k), employee stock ownership and 403(b) plans, as well as nonqualified deferred compensation arrangements. He also counsels privately and publicly held corporations and tax-exempt entities regarding fiduciary issues under the Employee Retirement Income Security Act (ERISA), employee benefits issues involved in corporate transactions, executive compensation matters and the implementation of benefit programs for domestic partners of employees.

Todd has significant ERISA Title I experience and has counseled plan fiduciaries with respect to investment policies, private equity, hedge funds, and other alternative investments, prohibited transaction issues, investment management agreements and payment of expenses from plan assets.

He advises multinational clients on global employee benefits matters and compliance issues. Todd is a council member of the International Bar Association Global Employment Institute (GEI) and serves as editor of the GEI’s Annual Global Report on global legal issues impacting human resources.

Todd represents clients before the Internal Revenue Service on issues such as Employee Plans Compliance Resolution System (EPCRS) filings, Audit Closing Agreement Program (CAP) negotiations, benefit plan audits and applications for determination letters. He negotiates with the Department of Labor in connection with benefit plan audits and Voluntary Fiduciary Correction Program filings, and the Pension Benefit Guaranty Corporation in connection with 4062(e) events and plan terminations.

Todd is the former head of the Firm's Pro Bono & Community Service Committee. He received the 2008 McDermott Will & Emery award for Outstanding Achievement and Commitment to Pro Bono and Service to the Community. Additionally, he is a member of the McDermott's Diversity and Inclusion Committee and has been involved with evaluating the Firm's domestic partner benefits policies and working with businesses in Chicago in jointly advocating for lesbian, gay, bisexual and transgender (LGBT) rights in the workplace.

Todd is a fellow of the American College of Employee Benefits Counsel, which recognizes attorneys who have made significant contributions to the advancement of the employee benefits field for at least twenty years. He is also ranked among the nations’ leading employee benefits and executive compensation lawyers by Chambers USA and The Legal 500 United States.

Kate Vera Coverdale focuses her practice on executive compensation matters related to mergers, acquisitions, joint ventures, restructuring plans, initial public offerings, carve-outs and other business transactions. She leads the employee benefits and executive compensation practice in our New York office.

Kate regularly counsels private equity firms and their portfolio companies, as well as public companies, individual executives and management teams, on all aspects of executive compensation across industries, including executive employment agreements, severance arrangements, incentive equity plans and other compensation programs. Clients rely on her nuanced counsel to navigate complex issues such as compliance with Internal Revenue Code Section 409A (relating to deferred compensation) and Internal Revenue Code Sections 280G and 4999 (relating to the deductibility limits on executive compensation and the excise tax imposed on excess parachute payments).

Kate has extensive experience advising on executive compensation issues in the bankruptcy, restructuring and insolvency contexts, helping clients navigate the challenges associated with implementing effective arrangements and retaining key talent in a distressed environment. She also advises clients regarding compliance with proxy disclosure and corporate governance regulations as they relate to executive compensation.

Kate is a member of Chief, a private membership network focused on connecting and supporting women executive leaders. She also speaks frequently to industry organizations on topics such as preparing for initial public offerings and executive compensation.

Joseph advises clients on all matters pertaining to the intergenerational transfer of wealth, including estate planning, succession planning, tax planning, trust and estate administration, audits, examinations, controversy avoidance and litigation. He also guides clients on the formation, governance and operation of private trust companies and family offices. His clients are located throughout the United States and include high-net-worth individuals and families, private trust companies, family offices, family office executives and large banks.

Joseph has successfully argued before trial and appellate courts in multiple jurisdictions. Due to his unique background in tax, planning and litigation, clients turn to Joseph to advise them in complex disputes involving family members, spouses, employees and business partners. A significant part of his practice involves counseling family offices and private trust company executives on strategies and best practices for avoiding personal liability. Joseph is frequently able to favorably resolve disputes without litigation. If necessary, however, he vigorously defends his clients’ interests in the courtroom.

Joseph is a frequent contributor to the bar. In addition to publishing numerous articles and book chapters, he is the principal draftsman of the forthcoming Michigan Trust Company Act. He also assisted with drafting the Michigan Uniform Fiduciary Income and Principal Act and the Model Civil Jury Instructions Regarding Undue Influence, among other legislative matters.

Thomas (Tom) P. Ward advises high-net-worth individuals and business owners on the income tax, corporate and compliance aspects of complex business and investment transactions, with a focus on family office management companies, private investment funds and complex incentive equity programs.

Tom has extensive experience in establishing and working with family offices and investment entities, ranging from first-generation entrepreneurs to multi-generational families, with net worth from $40 million to many billions of dollars, including a number of individuals listed in the Forbes 400. Tom works closely with the entire advisor team to implement the optimal structure for a particular situation and has extensive experience working with private trust company, airplane, transfer tax and security law considerations.

Tom is a frequent speaker on trends impacting family offices and high-net-worth individuals.

Ranked as “Band 1” by Chambers High Net Worth in its national Family Offices & Funds Restructuring category, clients praise Tom for being “a very thoughtful and knowledgeable attorney that truly understands the needs of an SFO. Tom's approach is very thoughtful and always tries to find creative ways to accomplish his client's goals."

While in law school, he was an editor of the Michigan International Law Journal.