Wealth Planning Commentary

This summer, those with vacation homes in New York City may have received letters in the mail from the city. Those letters are the first wave of enforcement for a new pied-à-terre surcharge that took effect July 1, 2026. Here's how it works: if a household owns a home in the city worth $5 million or more and doesn't use it as a primary residence, the city adds an annual surcharge on top of the regular property tax bill. Condos and co-ops currently trigger the surcharge at a much lower $1 million threshold, not because the policy targets smaller units, but because the city's valuation method for those properties runs well below true market value; a $1 million "city value" condo may really be worth $5 million on the open market. The rules run for five years before they're set to expire.

For years, the standard retirement advice was simple: max out your traditional 401(k), take the upfront deduction, and let Uncle Sam wait to tax your Required Minimum Distributions (RMDs) in retirement. Watching your taxable income shrink on your W-2 can feel like an immediate win. But if you follow this path for decades, you may arrive at retirement with a less welcome discovery: a portfolio that is almost entirely pre-tax is not a nest egg so much as an income tax bill in waiting. On top of that, if your heirs are non-spouses, they'll likely face the 10-year distribution rule on any pre-tax IRA they inherit, often during their own high-earning years.

For taxpayers with Opportunity Zone investments under the original program, the deferral window closes on December 31. Any capital gain deferred into a Qualified Opportunity Fund must be recognized as income this year, regardless of whether the investment has been sold or produced any cash to cover the tax. That gap between when the gain is taxed and when cash is actually on hand can create a liquidity crunch, and it's worth getting ahead of before year-end.

The Wall Street Journal recently spotlighted Private Placement Life Insurance (PPLI), describing it as a "Roth IRA on steroids" for wealthy Americans seeking tax-free growth. While the headline captures the imagination, PPLI is not a loophole or an aggressive tax shelter. In the eyes of the tax code, it is a variable universal life (VUL) insurance contract designed for Qualified Purchasers and Accredited Investors. It replaces the high-commission, off-the-shelf retail product with an institutionally priced, insurance wrapper that can invest in almost any asset class but is primarily used for tax-inefficient alternative assets.  

One of the more important decisions when setting up a trust is deciding who will actually administer it. Sometimes a family member is well suited to the role, but if not, there are reasons to consider a corporate trustee instead: no relative able or willing to take it on, complex assets that call for professional management, concern about future incapacity, or a blended family where a neutral party can help reduce friction. A corporate trustee is simply an institution, not an individual, that takes on the legal responsibility of managing a trust's assets and carrying out its terms.