Agenda
MONDAY, JUNE 5, 2017
7:00  9:00 pm
Welcome Reception at The Westin Philadelphia’s Georgian Room
TUESDAY, JUNE 6, 2017
Time
Topic
8:00  8:45 am
Registration and Breakfast
8:45  9:00 am
Welcome and Introductions
9:00  9:50 am
Current Developments Impacting Family Offices
This session will focus on recent developments in tax and property law
that are of particular significance to family offices. The speakers will
discuss the current state of federal tax reform and proposed changes to
state death tax laws, and will offer thoughts for planning in these
uncertain times. Other topics likely to be covered include the consistent
basis regulations, the state of valuation discounts, and recent rulings on
defined value clauses, intergenerational split dollar plans, and charitable
gifts.
9:50  10:00 am
Transition
10:00  10:45 am
How Did WikiLeaks Get My Emails? Best Practices in Family Office
Cybersecurity
This session will focus on cybersecurity risks affecting family offices and
their clients. The presenters will discuss the most pressing risks in this
area, including phishing attacks, targeted hacks, and identify theft. In
addition, the presenters will provide practical guidance to secure family
office operations as well as how to respond to breaches in security and
other incidents.
10:45  11:00 am
Break
Presenter
Carol A. Harrington
Nicole M. Pearl
Ann Killilea
Michael G. Morgan
Michael Rosen-Prinz
11:00  11:45 am
War & Peace… How to Avoid War While Resting in Peace
The presenters will briefly describe the estate administration process and
then share some “war stories” from which lessons may be learned. For
example, how do you avoid the children fighting over the art collection
upon mother or father’s death? How should you handle the passing of
voting control in the family business upon death? Consider a “dry run” to
walk through a simulated estate administration, and keep a “black book”
roadmap of what will happen upon the actual death.
11:45 am  12:45 pm
Networking and Peer Discussion Lunch
12:45  1:00 pm
Transition
1:00  1:45 pm
Breakout Session – Choose One of the Following:
Beyond Form 1040: Tax Compliance for U.S. Citizens and Residents
with Interests in Non-U.S. Property
Henry Christensen III
Jay E. Rivlin
Various Facilitators
Leigh-Alexandra Basha
M. Read Moore
Congress and the Treasury are keen to increase compliance by
taxpayers who own assets outside of the United States. This program
will cover important tax compliance issues for clients who have direct
and indirect interests in non-U.S. property and non-U.S. financial
accounts, including beneficiaries of foreign trusts and estates. Among
the topics addressed will be foreign bank account reports (FBAR),
disclosing ownership in non-U.S. companies, reporting distributions from
foreign trusts and estates, and the reporting requirements of the Foreign
Account Tax Compliance Act.
Is a Private Trust Company a Good Idea for my Family?
Private trust companies have become increasingly popular in the last
several years for many wealthy families. Should your family consider a
private trust company too? This session will explore the various reasons
families create private trust companies and the issues to consider when
determining if a private trust company is right for your family.
You Cannot Take it with You (So Why is it So Hard to Give Away)?
The Challenge of Giving Business Interests to Charity
Elyse G. Kirschner
Jonathan W. Motto
Neil T. Kawashima
Victoria Pambianco Ose
This program will address the tax and other problems associated with
giving business interests to charity both from the donor and recipient
standpoint. The presenters will consider several hypothetical situations
involving the transfer of operating businesses and family investment
funds to charity, and discuss potential solutions to the problems that
could arise.
1:45  2:00 pm
Break
2:00  2:45 pm
Breakout Session – Choose One of the Following:
No Visa for You! Navigating Immigration Issues in Today’s
Environment
Immigration issues are becoming increasingly common in wealthy
families. This presentation will discuss foreign household employees,
family members living abroad, nonresident spouses and other
immigration issues that the family office may encounter.
Joan-Elisse Carpentier
Katy Crafton Fluet
Pathway to a Successful Family Office: Key Considerations
This program will address key considerations in establishing a successful
family office, and will be helpful if you are establishing a new family office
or looking to keep up with family office best practices. The program will
highlight elements of successful family office structures, address
governing regulatory frameworks and explore various ownership and
governance approaches. The program will also dive into fee alternatives
and revenue options. Case studies will provide a lively discussion.
Silent Trusts: “Three Can Keep a Secret, if Two of Them are Dead”
Addressing ways to balance grantors’ desires to shield young
beneficiaries from potentially distracting wealth, while not creating
vulnerable trusts with nobody watching the store. This discussion will
focus on the developing rules on so-called “Silent Trusts,” as well as the
trustee’s job in navigating reasonable directions to manage information
with a beneficiary’s right to know.
2:45  2:55 pm
Break
2:55  3:40 pm
Peer Discussion Groups
3:40  3:50 pm
Break
3:50  4:35 pm
Beyond the Paycheck: Compensation Arrangements and Benefit
Plans for the Family Office
No matter how small or large, every family office must provide an
attractive compensation package and desirable benefit plan options if it
hopes to attract and retain top talent. This program will focus on common
compensation and benefits issues, unique challenges faced by family
offices and the solutions available for providing attractive retirement
benefits, health care coverage, and compensation packages to family
office executives and staff members.
4:35  4:45 pm
Break
4:45  5:30 pm
Breakout Session – Choose One of the Following:
“I Love You, I Do, but Please Sign Here.” A Primer on Premarital
Agreements
James H. Cundiff
Thomas P. Ward
David A. Baker
Jared R. Cloud
Nicole K. Mann
Various Facilitators
Bobbi J. Bierhals
Amy M. Gordon
Todd A. Solomon
Toni Ann Kruse
Sarah J. Robinson
This session is an introduction to premarital agreements (a.k.a.,
“prenups”), including their general legal requirements and best
practices. The presenters will cover when prenups are appropriate, how
prenups may be used to preserve family wealth and protect family
businesses, and creative solutions for discussing and setting
expectations for a prenup with family members.
Cutting-Edge Planning Ideas with Freeze Partnerships
“Freeze” partnerships have long been used as a strategy for achieving
significant transfer tax savings. This session will explore a select
sampling of cutting-edge strategies for using freeze partnerships to
achieve income and transfer tax savings and mitigate the risks
associated with tax law changes and shifting IRS priorities, with a special
focus on family-controlled businesses and dealing with low-basis assets.
5:30  7:00 pm
Break
7:00 pm
Dinner at the Mütter Museum
Richard L. Dees
Adam K. Sherman
WEDNESDAY, JUNE 7, 2017
Time
Topic
8:00  8:30 am
Breakfast
8:30  9:15 am
Direct Investing, from Structuring to Exit (and Everything in
Between)
Presenter
Mark S. Selinger
Jake Townsend
This program will address the multiple considerations to be taken into
account in structuring and implementing a variety of direct investment
transactions, including efficient tax structuring; management and control
issues; interaction with independent (“fundless”) sponsors; coinvestments; compensation of portfolio company management; transfer
restrictions; and liquidity alternatives.
9:15  9:25 am
Transition
9:25  10:10 am
Breakout Session – Choose One of the Following:
Achieving Family (Investment) Bliss – The Investment Partnership
Solution
Richard A. Lang
Patrick J. McCurry
This program will examine how family investment partnerships can
increase investment flexibility and efficiency. Case studies will provide
insight into structuring and tax considerations, as well as how the
investment partnership meshes with the family’s trust and wealth transfer
planning.
Private Aircraft – Maximizing Tax Benefits
Surprisingly, private aircraft can provide tax benefits. This session will
cover the federal tax consequences of business, personal, and
entertainment travel; the impact of state sales and use taxes; passive
activity grouping elections; and the “SIFL” rules, all illustrated by
common real life examples which private aircraft owners face. The
presenters will also examine how, given the right ownership structure
and use, there actually can be a partial tax deduction or reduction of
other taxable income for purely personal travel.
We Are Family… Taking Care of Business
No family is without conflict, but conflicts may be exacerbated when they
involve family-owned or family-run businesses. During this session, the
presenters will discuss some common, and not so common, family
business governance issues that often present conflict, and will offer
insights on both avoiding and dealing with these conflicts after they have
arisen.
10:10  10:20 am
Transition
10:20  11:05 am
Breakout Session – Choose One of the Following:
How to be a Trustee and Sleep at Night
So you have been named as trustee – now what? In 45 minutes, the
presenters will give you an overview of your responsibilities as trustee
and a checklist of potential issues to keep in mind while you are
administering a trust.
David P. DeYoe
Ruth Wimer
William J. Butler
Melissa Moszkowski Price
Christen Douglas
Laurelle M. Gutierrez
Private Trust Company 2.0 – The Evolution
What has happened in the private trust company space in the last year?
In this session we discuss recent developments, as well as the complex
issues faced by private trust companies today. The presenters will
explore questions related to indemnification and decision-maker liability,
situs concerns, multi-family trust companies, confidentiality, policies and
procedures updates, audits, and more.
What Family Office Leadership Needs to Know about Employment
Issues: a High-Level Employment 101
Family office leadership should have a working knowledge of
employment issues - both those impacting the family for whom he/she
works, and those impacting staff at the family office. This session will
focus on issues unique to family (domestic) employees such as the Fair
Labor Standards Act (“FLSA” - overtime and exceptions for domestics),
classification issues (employee versus independent contractor), and
liability issues. It will also address issues related to more high-level
employees of the office, including hiring, compensation (FLSA exemption
issues), performance reviews, terminations and employment-related
liability issues.
11:05  11:15 am
Transition
11:15 am  12:00 pm
Breakout Session – Choose One of the Following:
Avoiding Securities Laws Pitfalls
This session will synthesize the securities laws so that you can:

detect and avoid potential pitfalls when creating trusts (including
GRATs) and other investment vehicles, as well as when making
transfers;

understand how securities ownership is calculated for different
purposes and different types of entities and relationships, so that
you do not engage in problematic transactions and you report
holdings and transactions in the most advantageous way; and

know how to navigate those pesky investor questionnaires.
Boosting the Bang for Your Buck: Valuation and Discounts
This program will focus on drafting considerations in family business
agreements which affect valuation discounts and tax exclusions,
planning pitfalls producing mismatches between gift/estate tax values
and charitable or marital deductions, issues in valuation of special assets
(such as intra-family notes and companies with built-in gains) and postdeath issues in choosing the valuation date and coordination with basis
planning.
L. Timothy Halleron
Elise J. McGee
Linda M. Doyle
Kerry Alan Scanlon
Jeremy White
Anne G. Plimpton
Michael J. Sorrow
David A. Herpe
Julie Miraglia Kwon
Thinking Beyond Uncle Sam: State Taxation of Trusts and
Minimizing its Impact
Ellen K. Harrison
Shu-Ping Shen
State income taxation of trusts is sometimes a secondary consideration
to federal taxation of trusts, but disregard of state taxation rules will likely
lead to adverse tax results. Ignoring state income tax planning could, for
example, result in taxation by a state that might not seem to have a close
connection to a trust or taxation by multiple states that do not provide
credit for taxes paid in other states. This presentation will discuss the
constitutional basis for and recent case law regarding state income
taxation of trusts. From there, the presenters will explore the various
approaches that states use to determine whether a trust is subject to
state income tax. Using this background, the presenters will then
consider certain techniques that can be used to minimize the impact of
state income tax.
12:00  12:05 pm
Transition
12:05  12:50 pm
Getting Gratifying GRAT Results
This presentation will focus on techniques for enhancing the likelihood
that a GRAT will produce a positive balance at the end of the term,
including the use of split-interest and leveraged GRATs. The
presentation will also explore the possibilities of protecting a GRAT’s
positive balance from the generation-skipping transfer tax.
12:50  1:30 pm
Closing, Participant Survey, Lunch and Departure
Times subject to change.
Jeanette Suarez Hunter
Carlyn S. McCaffrey
PEER DISCUSSION GROUP TOPICS
Aircraft Ownership – What issues (tax, flight crew, maintenance, aircraft availability/sharing, etc.) have you encountered
and how did you deal with them?
Collaboration/Harmony Within the Family – How are you fostering it?
Creating a Private Trust Company – A discussion of your thought process for why you want to create (or did create)
a PTC, the issues you experienced, and the rewards you reaped.
Cybersecurity – How is your office protecting the family’s data?
Direct Investing – A discussion for family offices investing in operating companies.
Direct Investing – Real Estate – A discussion for family offices specifically interested in real estate investments.
Educating the Next Generation – What has worked for you? What has not?
Family Business Succession – How are you planning for it?
Family Office Technology and Software – What has improved the functioning of your office?
Hiring Family Office Personnel – How do you find qualified applicants, vet them, onboard them, compensate them
and retain them?
Internal Controls in Your Family Office – What controls are you utilizing?
Managing Audits and Tax Litigation – Share your war stories.
Operating the Family Office with Profits Interest Structure – A discussion of the pros and cons. Share your
thoughts and experiences.
Private Foundation Operations – A discussion of the grant-approval process, internal controls and staffing that you
utilize. How and when do you (did you) involve the next generation?
Serving Millennial Clients – What have you found works best for engaging and serving this generation of clients of
the family office?
Your Private Trust Company – A discussion of the internal controls, staffing and procedures that you utilize.