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Corporate Transparency Act Update: What to do now?

Updated March 3, 2025

Businesses and professionals are scrambling to keep up with the shifting legal landscape as the Corporate Transparency Act (CTA) undergoes significant – i.e., multiple on again, off again – changes. It appears that the CTA is now permanently off as a result of a March 2, 2025, Treasury Department announcement saying Treasury would not enforce the CTA except as to foreign reporting companies (i.e., non-U.S. business entities that are registered to do business with any U.S. Secretary of State). 

What is The Corporate Transparency Act?

The CTA was passed into law as part of the National Defense Authorization Act for Fiscal Year 2021. The CTA requires most U.S. and some foreign business entities to report their “beneficial owners” to the Financial Crimes Enforcement Network (FinCEN) for the purpose of combating money laundering and terrorism financing; if the business entity is registered with any U.S. Secretary of State or similar agency, it is considered a “reporting company” and likely must file a beneficial owner information report (BOIR) with FinCEN. If a beneficial owner’s information changes, the reporting company must file an updated report with the new information.

Significantly, foreign and domestic business entities that are not registered with any U.S. Secretary of State’s office are not considered reporting companies and are not subject to the reporting requirements of the CTA.

Reporting Companies and Their Obligations

Reporting companies created before January 1, 2024, originally had until December 31, 2024, to report their beneficial owners, but effective January 1, 2024, new reporting companies were required to file within 45 days of the creation of the reporting company by the original filing with a Secretary of State. According to FinCEN’s FAQs, any person who willfully violates the CTA’s reporting requirements may be subject to civil penalties of up to $500 (indexed for inflation) for each day that the violation continues. A person who willfully violates these reporting requirements may also be subject to criminal penalties of up to two years imprisonment and a fine of up to $10,000. Potential violations include willfully failing to file a beneficial ownership information report, willfully filing false beneficial ownership information, or willfully failing to correct or update previously reported beneficial ownership information.

However, via Press Release dated March 2, 2025, the Treasury Department announced that it will not enforce the CTA except as to foreign reporting companies (i.e., non-U.S. companies that register with a U.S. Secretary of State).

Determining Beneficial Owners & Reporting Requirements for Different Entities

As to determining beneficial owners, a reporting company must report the individuals who either (1) exercise substantial control over the reporting company or (2) own or control at least 25 percent of the ownership interests in the reporting company.

Those who exercise substantial control over the reporting company are those individuals who are a senior officer (e.g., the company’s president, chief financial officer, general counsel, chief executive officer, chief operating officer, or any other officer who performs a similar function), those who have authority to appoint or remove certain officers or a majority of directors (or similar body) of the reporting company, and the important decision-makers for the reporting company. According to FinCEN’s FAQs, important decisions “include decisions about a reporting company’s business, finances, and structure. An individual that directs, determines, or has substantial influence over these important decisions exercises substantial control over a reporting company.” Thus, a reporting company must include as beneficial owners its Managers if an LLC, its general partners if a limited partnership, and its President or CEO and CFO, CLO, etc. if the reporting company is a corporation.

If the reporting company is owned at least 25% by another reporting company, the report must include all of the owner reporting company’s beneficial owners in its report. Alternatively, the report may include the owner’s FinCEN identifier, which includes all of its beneficial owner information. If at least 25% of the reporting company is owned by a trust, the reporting company must report as beneficial owners the trust’s Trustee, the trust’s beneficiary (if there is only one beneficiary), and the trust’s settlor if the trust is a revocable trust. Learn more about how trusts are affected by the CTA here.

Corporate Transparency Act: Injunctions, Appeals Court, and Ongoing Enforcement Challenges

Since its passage into law, critics have argued that the CTA is unnecessary, given that much of this information is already collected elsewhere, and further, that the CTA is an unconstitutional infringement on the beneficial owners’ right to privacy.  Thus, numerous lawsuits have been filed nationally seeking to prevent enforcement of the CTA, and several lower courts have issued injunctions preventing such enforcement. One such case (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas Top Cop Shop v. Garland) was appealed all the way to the U.S. Supreme Court, where on January 23, 2025, the Court granted the government’s motion to stay the nationwide injunction issued by a federal judge in Texas. In other words, the Supreme Court ruled that FinCEN could proceed with CTA reporting enforcement.

However, on January 7, 2025, a second Texas court had also issued a national injunction in Smith, et al. v. U.S. Department of the Treasury, et al., on February 5, 2025, the Department of Justice—on behalf of the Department of the Treasury—filed a notice of appeal of the district court’s order and, in parallel, has sought to stay that order as the appeal proceeds. In a recent Alert, FinCEN indicated that it intends to enforce the CTA reporting requirement if the injunction is lifted in the Smith case:

“If the district court’s order is stayed, thereby allowing FinCEN’s Reporting Rule to come back into effect, FinCEN intends to extend the reporting deadline for all reporting companies 30 days from the date the stay is granted (emphasis added).”

Then, on February 18, 2025, the court in Smith stayed its injunction as a result of the Supreme Court’s ruling in Texas Top Cop Shop. Not surprisingly given FinCEN’s statement above, on February 19, 2025, FinCEN announced the commencement of the 30-day window to file such that for most reporting companies all initial, updated, and/or corrected beneficial ownership reports are due no later than March 21, 2025.

Thereafter, on February 27, 2025, FinCEN announced that it would NOT enforce the March 21, 2025, deadline and that it would issue further guidance by that same date.

Then, on March 2, 2025, the Treasury Department (which oversees FinCEN) issued a Press Release saying it would not “ … not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners” and that it would be issuing new rules limiting the application of the CTA to foreign reporting companies. Thus, as of March 2, 2025, the CTA is off again unless the business entity is a foreign reporting company.

Corporate Transparency Act: How to File

Presuming that the reporting requirements will commence eventually, the best preparation for the filing of the FinCEN beneficial owner report is to obtain a FinCEN Identifier for all of the reporting company’s beneficial owners. The FinCEN FAQs explain this process succinctly:

“Individuals may request a FinCEN identifier … by completing an electronic web form at https://fincenid.fincen.gov. Individuals will need to provide their full legal name, date of birth, address, unique identifying number and issuing jurisdiction from an acceptable identification document, and an image of the identification document. After an individual submits this information, they will immediately receive a unique FinCEN identifier.”

Rather than providing all of the above information in the beneficial owner report, the reporting company need only provide the FinCEN identifier for each beneficial owner, thereby greatly simplifying the reporting process. Further, by using FinCEN identifiers, if a beneficial owner updates his or her FinCEN identifier information, that update will automatically apply to any reporting company’s report which includes that beneficial owner, thereby eliminating the reporting company’s duty to file an updated report.

To file a beneficial owner report, visit FinCEN’s CTA website at https://www.fincen.gov/boi and click on the “File a report using the BOI E-Filing System.” Note that the link to obtain a FinCEN identifier, discussed above, is immediately below.

Click on the link that reads “BOI E-Filing: Beneficial Ownership Information (BOI) Reporting, Get Started.” You now have the option to either complete and file the report in pdf (hardcopy format) or online electronically. There is no difference in the information requested – in fact, the pdf version is identical to the online form, although the pdf option gives you an easy record of your filing. Select the option that is most comfortable for you.  If you select the pdf option, it will download the pdf form. If you select the electronic option, you will be taken to a secure site that tracks the pdf form.

Either way, follow the prompts and complete the requested information. Under Part 1, Reporting Company Information, be sure to select “Request to Receive FinCEN Identifier (FinCEN ID)” for the reporting company, which will simplify filing updates in the future, if necessary.

For detailed, step-by-step filing instructions, visit https://boiefiling.fincen.gov/resources/BOIR_E-File_PDF_Step-by-Step_Instructions.pdf

We’ll continue to provide CTA updates as needed. For more information, visit the beneficial owner information page of FinCEN at https://www.fincen.gov/boi.

This article is intended for informational purposes only. The information shared reflects an evolving situation and does not represent a guarantee or prediction of future outcomes. The results described may not be typical or applicable to every client or situation, and individual results may vary based on a variety of factors. Any decisions made based on this information should be considered in the context of your specific circumstances and investment objectives. Please consult with your investment adviser for personalized advice.

The American Dream is Evolving: Diversifying Beyond Homeownership

In recent weeks, we’ve witnessed devastating fires raging through parts of California, leaving countless families facing the unimaginable. For many, their homes—long seen as the cornerstone of the American Dream—were reduced to ash. It’s a stark reminder that while homeownership is a worthy goal, it shouldn’t be the only focus of our financial journey.

As we move forward, it’s essential to ask ourselves: Are your assets truly protected? Are they diversified in ways that minimize risk? And perhaps most importantly, are you setting up a financial legacy that will ensure your children are well taken care of, no matter what challenges arise in the future?

The harsh reality is that we live in a world where natural catastrophes—like the hurricanes that have impacted Florida or the wildfires in California—are becoming more frequent. With the unpredictability of climate change, geopolitical shifts, and economic volatility, it’s more important than ever to take a proactive approach to your financial planning.

The Power of Diversification

While homeownership has long been a central pillar of financial success, it’s crucial to understand that wealth should be built on a foundation that includes a variety of assets. Diversification is one of the most powerful tools you can leverage to safeguard your wealth. By allocating assets across different investment vehicles—such as stocks, bonds, real estate, gold, Bitcoin, private credit, municipal bonds, and other assets globally you can manage your risk more effectively. This way, even if one sector or geography faces challenges, your broader portfolio remains strong.

Creative Solutions for Liquidity

It’s also important to pay attention to liquidity, but this doesn’t just mean having cash on hand. In fact, one of the most creative ways to address liquidity is by designing a portfolio that can solve for specific needs, such as income generation or funding yearly expenses for your estate. Liquidity is not just about immediate access to cash—it’s about building a portfolio that provides flexibility and access to resources when you need them most.

For example, you can strategically incorporate income-generating assets like private credit, municipal bonds, and dividend-paying stocks, all of which can provide consistent cash flow for ongoing expenses or emergencies. You can also create liquidity through the careful use of non-traditional assets like gold or cryptocurrency, which may be liquidated or converted to cash in times of need or in times of opportunity. Having liquidity means optionality. The key is to think creatively about how your investments can work together to create a comprehensive strategy that meets your cash flow needs while continuing to appreciate over time.

This approach goes beyond just thinking about the stock market or homeownership—two options that are often seen as the default. With the right balance of liquid and illiquid assets, you can build a portfolio that not only protects and compounds wealth but also provides the necessary liquidity to meet your financial goals and those of your heirs.

Protecting Your Legacy with Trusts

One of the most challenging aspects of natural disasters for parents is the worry about what will happen to their children if there is no house to pass down. The loss of a home can feel like the loss of a family legacy—something built with years of effort and sacrifice. But it’s important to remember that your legacy is not limited to real estate. There are many ways to ensure that your children are taken care of, even if a house is no longer part of the equation.

A well-structured trust can be an incredibly powerful tool for protecting your wealth, no matter the asset type. In fact, trusts can hold a wide variety of assets—ranging from real estate to stocks, bonds, gold, Bitcoin, private credit, and even business interests. By placing these assets into a trust, you can not only protect them from creditors, probate, and potential disputes, but you can also ensure that they are distributed according to your wishes.

This strategy allows you to create a legacy for your children and future generations, offering them financial security and peace of mind, no matter what happens to your home. Whether it’s an inheritance of diversified investments, income-generating assets, or other appreciating assets, a trust ensures that your legacy is preserved and protected.

Building Resilience Through Financial Well-Being

In times of uncertainty, it’s natural to feel anxious, especially when your home, your investments, and your future seem vulnerable. But just as we focus on mental well-being to build resilience and cope with stress, the same approach can be applied to our financial well-being. Money, after all, is one of the leading sources of anxiety for many people.

Building a resilient financial foundation—through diversified assets, trust structures, and strategic planning—can offer peace of mind in the face of adversity. It’s about creating a financial framework that supports you through life’s uncertainties, just like mental wellness strategies help us navigate emotional challenges. The more you can plan, diversify, and protect your wealth, the more resilient and confident you’ll feel, even when the unexpected happens.

Start the Conversation Today

The recent events in California and Florida remind us all of the importance of being prepared. If you’re ready to explore how diversification, trust structures, and other wealth-preserving strategies can help secure your financial future, we invite you to start a conversation with us.

Together, we can create a roadmap that not only helps protect your wealth but also gives you the freedom to focus on what truly matters—your family, your passions, and your legacy.

Let’s take the next step in your financial journey—one that goes beyond homeownership and secures a future built on strength, stability, and peace of mind.

If you’re interested in learning more about Bespoke’s approach to private wealth management and how we can help you build a secure financial future, we invite you to reach out to us directly. We’d be happy to set up a confidential consultation at your convenience.

Thank you for considering Bespoke as your partner in wealth management. We look forward to the opportunity to work with you.

The following information is intended for general educational purposes only and should not be construed as legal or investment advice.

Wealth Optimization Strategies for Bitcoiners with Will Foxley on The Mining Pod

On this episode of The Mining Pod, Bespoke’s Founder, Matthew McClintock, and Client Services and Trading Support Associate, Jack Jones, sit down with Will Foxley to discuss stock option wealth planning, BTC income planning, early estate planning, and much more. Watch the full video here.

Digital assets like Bitcoin and mining stocks can be part of a strategy aimed at potential growth and long-term wealth preservation, while helping to build a lasting legacy. Our family office and advisory service is tailored to help individuals manage their wealth responsibly, from optimizing tax strategies to designing custom trust structures aimed to preserve privacy and promote seamless asset transfer. This episode unpacks critical strategies like estate planning, charitable giving, and revocable trusts that help avoid probate, maintain privacy, and minimize tax burdens.

Financial Sovereignty Beyond Self-Custody

Achieving greater financial control goes beyond just holding your Bitcoin keys—it’s about preparing for the future with intention and a well-rounded strategy. Without a structured plan, unexpected events like illness or death can leave your loved ones navigating public, court-supervised processes. A trust offers a private, enforceable way to protect your assets and ensure your wishes are honored. At Bespoke Group, we help Bitcoiners create tailored strategies focused on preserving autonomy, privacy, and long term wealth, helping you navigate the complexities of digital assets beyond self-custody.

Strategic Custody Solutions

As Bitcoin’s value grows, so does the need for secure, well-planned custody. While “being your own bank” works for smaller holdings, large Bitcoin stacks require a more strategic approach to mitigate risks and ensure continuity. Bespoke helps Bitcoin holders implement cascading multisig setups and estate-focused trusts, balancing sovereignty with trusted oversight. Thoughtful planning can help secure your assets, minimize tax exposure, and support long-term wealth preservation, allowing you to maintain greater control over your financial future. 

Strategic Planning for Protecting Gains and Supporting Long-Term Wealth for Bitcoin Founders

Planning for Bitcoin equity gains and private company assets requires a flexible, forward-looking approach. Whether you’re holding founder stock, RSUs, or Bitcoin mining equity, it’s important to start with clear financial goals for the wealth you accumulate. If you plan to cash out and enhance your lifestyle, prioritize strategies for privacy and asset protection. But if your focus is on long-term family wealth, consider setting up a dynasty trust to shelter assets from estate taxes across generations.

For Bitcoin miners and similar ventures, strategy involves balancing rewards and equity gains. You’ll need to decide how much wealth to retain in the company versus what to distribute as personal income, which affects both taxes and reinvestment potential. Ultimately, define your end goal first. This sets a foundation to adapt your wealth strategy over time, ensuring that every decision aligns with your vision for the future.

Navigating the complexities of Bitcoin, equity gains, and estate planning requires a thoughtful strategic approach to help manage your assets effectively and support their transfer to future generations. At Bespoke Group, we specialize in helping individuals plan for the long-term, balancing financial sovereignty with trusted oversight. Whether you’re a Bitcoin holder, a founder with significant equity, or someone seeking to build generational wealth, our tailored strategies empower you to build a lasting legacy, minimize tax burdens, and achieve your financial goals with confidence.

This information is intended for general educational purposes only and should not be construed as legal or investment advice. Investing in digital assets such as Bitcoin and other cryptocurrencies involves significant risks, including volatility and potential loss of principal. Secure custody is an important part of a strategy, but it does not eliminate risks. These assets may not be suitable for all investors. Please carefully review your risk tolerance and consult a financial advisor before making any investment decisions.

The Potential Implications of the Corporate Transparency Act (“CTA”) on Individual Privacy

What is the Corporate Transparency Act?

On January 1, 2024, the Corporate Transparency Act (“CTA”) went into effect, requiring the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) to collect beneficial ownership information (“BOI”) from corporations and limited liability companies (“LLCs”) registered in the U.S. 

A beneficial owner is an individual who, directly or indirectly, exercises substantial control over a “reporting company” or who owns or controls at least 25% of the ownership interests of the company. The mandatory disclosures include the individual’s full legal name, date of birth, address, and a unique identifying number such as an EIN or Social Security number, or an identification number issued by FinCEN. BOI information is reported through the Beneficial Ownership Secure System (“BOSS”), which is a “a non-public, secure registry” managed by FinCEN.

The cost of non-compliance can be highly punitive: Failure to disclose the required information to FinCEN may be subject to severe civil and criminal penalties, including a fine of up to $250,000 or imprisonment up to five years.

What is Considered a Reporting Company?

The CTA regulations apply to “reporting companies,” which are further delineated as Domestic and Foreign Reporting Companies. Virtually any company established by filing organizational documents with a Secretary of State of any U.S. state is a “reporting company” and is subject to the reporting requirements. Even single member or trust-owned LLCs created anywhere in the U.S. are subject to the disclosure rules.

Almost all U.S. domestic LLCs are Domestic Reporting Companies, even if they were only established for personal wealth structuring purposes.

A Foreign Reporting Company is an entity established outside the U.S. that is registered to do business with a Secretary of State (or equivalent office). Foreign companies that are not required to register to “do business” are NOT foreign reporting companies under the CTA regulations. Each state’s statutes and the rules enacted by the various secretaries of state determine what level of activity constitutes “doing business” in the state. If a particular locality does not require a foreign company to register to do business, it is not considered a Foreign Reporting Company under the CTA regulations.

How Are Trusts Affected by the CTA?

Importantly, trusts are not “reporting companies” and are not subject to the CTA disclosure rules. Of course, there are scores of different types of trusts and many attractive trust jurisdictions that may provide appropriate planning solutions. The tax characteristics, privacy, and protection offered by a trust depends entirely on the type of trust, where it’s established, and how it’s managed.

Planning for non-disclosure of beneficial owner information to the FinCEN database requires careful analysis to determine if the foreign entity is exempt from the disclosure rules or if a certain type of trust framework achieves broader wealth planning objectives. Clients who place a high premium on privacy and who wish to keep their personal information out of a national “Financial Crimes” database should seek legal counsel to determine how to structure their entities with the CTA in mind. Bespoke Group actively works with its clients to navigate these reporting requirements while optimizing for privacy. 

Why FinCEN’s Regulations Endanger the Right to Privacy 

For decades, LLCs have been used both to enhance asset protection and to provide privacy for personal use holdings like vacation homes, non-mortgaged primary homes, or personal & family investment portfolios. It has been standard wealth planning practice to use trust-owned LLCs in robust privacy jurisdictions like Wyoming or South Dakota to allow affluent clients to hold real estate or other family assets in private structures, often within tax-advantaged irrevocable trusts. Financially and commercially successful individuals understandably seek to preserve their privacy and protect themselves and their family from curiosity seekers or from those with nefarious intent to harm the client or the client’s family.

The requirement for LLCs created and registered in the U.S. to report personal information to a federal database managed by the Financial Crimes Enforcement Network raises valid concerns for individuals focused on protecting their privacy.

These regulations and reporting processes may significantly affect the right to privacy for many individuals and families in the U.S. Personal information stored within a financial crimes database is not guaranteed to be protected from a data breach, and digital records are effectively permanent historical and traceable records. Furthermore, with these regulations in place, efforts to protect one’s privacy through an LLC structure puts individuals in the uncomfortable position of being tracked within a financial crimes database. Many people prefer the ability to protect their privacy without coming under the scrutiny of financial crimes enforcement agencies or any type of criminal enforcement agency.

A Precedent Has Been Set

Another important factor to consider is the potential expansion of this act over time, resulting in additional beneficial ownership information being collected at the federal and state level. Now that a precedent has been set, expanding the scope of information that could be collected in the future is potentially a lower hurdle.

Since the initial rollout of the CTA, various states have been working on their own reporting requirements, often focusing on narrower categories of “reporting companies”. In addition to placing greater administrative burdens on individuals and corporations, state-level BOI collection will likely raise concerns regarding privacy and could potentially increase the risk of data breaches as this information is stored in a separate database. Moreover, states may implement more frequent data collection timelines, and companies that do not adhere to these requirements could face additional fines and penalties.

Our Focus on Privacy

Privacy is generally understood to be a fundamental human right and preserving and protecting the privacy of our clients is central to our services. Our team is dedicated to providing industry-leading wealth management solutions, and privacy is a key factor in every decision we help our clients make. The Corporate Transparency Act presents new challenges for our industry, and in an ever-changing regulatory environment, Bespoke will always look for opportunities to optimize for privacy while maintaining compliance with existing regulations.

Additional Resources: FinCEN Beneficial Ownership Reporting

FinCEN Beneficial Ownership Information Reporting Rule Fact Sheet
https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet

FinCEN Beneficial Ownership Information FAQ
https://www.fincen.gov/boi-faqs

Beneficial Ownership Reporting Outreach and Education Toolkit
https://www.fincen.gov/boi/toolkit

If you’re interested in learning more about Bespoke’s approach to private wealth management and how we can help you build a secure financial future, we invite you to reach out to us directly. We’d be happy to set up a confidential consultation at your convenience.

Thank you for considering Bespoke as your partner in wealth management. We look forward to the opportunity to work with you.

This information is intended for general educational purposes only and should not be construed as legal or investment advice.

Enhance Your Philanthropy and Tax Planning with Strategic Giving Tools

On Day 3 of the Onchain Giving Summit hosted by Endaoment, Bespoke founder Matt McClintock speaks to Adam Blumberg, Bespoke Client Services Associate and co-founder of Interaxis, about the importance of incorporating philanthropy into estate planning.

Navigating the intersection of charitable giving and tax planning can unlock significant financial and philanthropic opportunities. Whether you’re looking to maximize your tax benefits, manage appreciated assets, or support causes you care about, various strategies can enhance both your financial plan and charitable impact.

Maximizing Tax Benefits Through Charitable Giving in Estate Planning

Charitable giving is a powerful way to support causes you care about, and it can also play a key role in estate planning. Whether making outright gifts to family members or donating to charitable organizations, there are significant tax benefits available. For cash gifts to qualifying charities, you can deduct up to 60% of your adjusted gross income (AGI). Donations of property, such as real estate, offer deductions ranging from 20% to 50% of AGI, depending on the type of asset and charity. Thoughtful philanthropy not only helps others but can also create lasting tax advantages for your estate.

Navigating Charitable Donations of Cryptocurrency: Timing and Appraisals

When donating cryptocurrency or digital assets to charity, it’s essential to establish the value at the time of the gift. For tax deduction purposes, the gift must be supported by a qualified appraisal, just like any other donation. Fortunately, there are expert appraisers who specialize in valuing digital assets like Bitcoin, ensuring accurate reporting for charitable contributions.

Raise Your Charitable Impact with a Donor-Advised Fund

Donor-advised funds (DAFs) are a smart, flexible option for individuals looking to make large charitable gifts but aren’t yet sure where to direct the funds. After experiencing a major income tax event, many donors want to secure a significant charitable deduction without needing to decide immediately which charities to support. A DAF allows donors to contribute now, receive the tax benefit, and take their time selecting causes to fund later. It’s an ideal solution, especially when gifting non-traditional assets like cryptocurrency. With tools like DAFs, philanthropy becomes more adaptable, offering greater control and financial benefits for donors.

Leverage Charitable Lead Trusts for Tax Benefits and Future Generational Wealth

A charitable lead trust offers a strategic way to support charities while benefiting your heirs. By establishing this trust, you direct it to make fixed annual payments to a qualifying charity, such as a donor-advised fund or family foundation, for a specified term (e.g., 10 or 20 years). At the end of this period, any remaining trust assets transfer gift-tax-free to your chosen beneficiaries, like your children. Additionally, you can receive an upfront tax deduction based on the trust’s initial value. This setup not only supports charitable causes but also provides tax advantages and protects your heirs’ future interests.

Unlock Tax Benefits and Charitable Impact with a Charitable Remainder Trust

A Charitable Remainder Trust (CRT) is a savvy tool for managing appreciated assets like Bitcoin or ETH while supporting charitable causes. By transferring these assets into a CRT, you avoid immediate capital gains taxes when the trust sells them. Instead, you receive an income stream from the trust for a set period or for life. At the end of this term, the remaining assets go to your chosen charity. This strategy not only maximizes your charitable impact but also provides you with tax benefits and ongoing income, making it a powerful option for both philanthropy and financial planning.

This information is intended for general educational purposes only and should not be construed as legal or investment advice.

How Small PMWs and MFOs Can Provide Greater Value than Large Institutions

Large financial institutions are often known for their global reputation, robust resources, and established trust. But when managing significant wealth, it’s critical to look beyond the name and ask these questions to truly understand who is helping manage your wealth.

  1. How do you ensure that your unique interests are prioritized?
  2. Are the relationships with your advisors meaningful and built to last?
  3. Is the institution’s commitment to your success consistent and aligned with your long-term goals?

These are questions worth considering regardless of the size of the wealth manager. However, they are easier to answer when you work directly with individuals who understand your personal journey and are invested in your future. This is where smaller Private Wealth Managers (PWMs) and Multi-Family Offices (MFOs) offer distinct advantages.

Alignment of Interests and Incentives

Large financial institutions often have proprietary investment funds they are incentivized to promote. This can complicate decisions about what’s best for the client. We do not offer any in-house investment products, nor do we have investment quotas. Our sole focus is on providing strategic guidance that aligns with the client’s personal objectives.

Another way we align our services with our clients is by operating on a fixed-fee model rather than hourly rates. This approach encourages a regular and ongoing dialogue with our clients and allows flexibility to modify strategies as needed. This model reduces any stress or concern about billable hours and helps us to focus on the client’s long-term success.

We measure success not by assets under management but by the impact we help our clients create.

Discretion and Privacy

Discretion and privacy are often underappreciated in wealth management but can be critical when it comes to inheritance and legacy planning. Large institutions often do not prioritize privacy in a way that smaller firms do.

At Bespoke, we emphasize discretion throughout the wealth management and inheritance transfer process. From safeguarding your assets from potential creditors to structuring your inheritance to avoid public judicial proceedings, our strategies are designed with privacy in mind. We believe in taking ownership of this process and being proactive to ensure that you retain as much control as possible over how your wealth is distributed.

Self-sovereignty is planning for and exercising your ability to maintain control of the process and keep your financial affairs outside of the public court system. Working with a small, trusted team of advisors like ours allows for more careful planning, ensuring that your personal affairs remain private, both during your lifetime and after.

A Personal Approach and Building Long-Term Relationships

It can be easy for large institutions to fixate on investment returns and lose sight of what matters most—your legacy, values, and protecting your family’s future. Achieving this depth of understanding can be challenging with larger institutions, where the relationship may feel impersonal and transactional.

Wealth management should be considered in the context of how you can live the best version of your life by leveraging your wealth and creating a framework for your family and future generations to do the same. Clients must think deeply about what their wealth means to them. At Bespoke we ask our clients ‘what kind of life do you want your children to have? How can you ensure that your values are passed on and respected?’ Legacy planning is about properly preparing the transfer of ownership to future generations in a thoughtful and organized way. For a thoughtful conversation on these topics, please listen to our Co-founder Matt McClintock’s conversation with Jacob Shapiro (Head of Geopolitical & Macro Research, Senior Client Relationship Manager, Bespoke) on The Jacob Shapiro Podcast – Matt McClintock: The Good Life and Personal Sovereignty: Introducing Bespoke.

Smaller MFOs focus on building long-term relationships with a foundation of trust and respect. By deeply understanding the client’s family dynamics, personal goals and financial aspirations, we create tailored strategies that reflect not just financial goals but generational legacies. This is difficult to replicate at larger institutions, where the volume of clients and conflicting priorities can dilute personal attention.

Comprehensive and Holistic Planning

There are many variables at play and implications to consider in estate planning, with smaller PWMs and MFOs uniquely positioned to offer guidance and planning that is more thoughtful and holistic. Larger institutions may offer similar services, but smaller firms with highly experienced and knowledgeable advisors excel in designing comprehensive, cohesive and one-of-a-kind wealth strategies.

At Bespoke, we offer a fully integrated service that includes investment management, tax mitigation, estate planning, philanthropic strategies, and specialized asset protection. Our clients often seek privacy, the protection of wealth from predators, family-controlled governance structures, and customized solutions to manage complex or concentrated assets.

We also work closely with clients to strategically deploy financial capital to their communities in ways that align with their values. In The Last Trade: The Bitcoin Heritage Blueprint with Matt McClintock (1:25:05), Matt describes multiple examples of UHNWIs who have made commitments to improve communities that are deeply important to their lives.

Customized Investment Solutions

Smaller PWMs and MFOs often provide more flexible and tailored investment strategies than large institutions, which can be limited by standardized offerings. At Bespoke we can design strategies that reflect our client’s unique risk profile, family dynamics, and long-term goals. We aren’t bound by institutional mandates or investment quotas, allowing us to focus entirely on what makes sense for each client.

This includes managing risk across multiple jurisdictions, creating investment opportunities in emerging markets or alternative asset classes, and leveraging opportunities that large institutions may overlook due to their scale. We maintain a broad view of markets, new technologies, and global opportunities, balancing these with a long-term perspective on risk management. Our expertise in legal and tax strategies enables us to navigate even the most complex situations.

For example, we work with a number of early bitcoiners who understand the trajectory of this new asset class. Working with and prioritizing an allocation to bitcoin while it’s experiencing its monetization phase is incredibly important when considering asset allocation. We’re able to step back and understand the opportunity cost of premature portfolio rebalancing in this environment.

Flexibility and Iteration

Wealth management is a dynamic process. Everything in life is subject to change, often in ways we can’t control. Markets shift, regulations change, and family circumstances evolve. We believe wealth planning is an iterative process that requires ongoing dialogue. Our strategies are designed to be flexible, allowing us to make adjustments as family requirements change.

This level of adaptability is often harder to achieve with larger institutions, where processes are more rigid and transactional. Smaller PWMs and MFOs excel in maintaining this level of flexibility, allowing them to better serve clients in an ever-changing environment.

The most important thing to consider with estate planning is that every individual and family has unique needs and deserves a thoughtful well-designed wealth management strategy. Smaller PMWs and MFOs have proven time and again that they can provide an equal level of services that are often more personalized and customizable.

If you’re interested in learning more about Bespoke’s approach to private wealth management and how we can help you build a secure financial future, we invite you to reach out to us directly. We’d be happy to set up a confidential consultation at your convenience.

Thank you for considering Bespoke as your partner in wealth management. We look forward to the opportunity to work with you.

The following information is intended for general educational purposes only and should not be construed as legal or investment advice.