230: Self-Directed IRA vs. Traditional IRA: What’s Better for Alternative Investing?
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Are you looking to seize control of your retirement funds and explore alternative investment avenues beyond traditional stocks? In this episode, Adam Bergman, a nine-time author, former tax and ERISA attorney, and founder of IRA Financial, shares how self-directed IRAs can empower you to invest in assets like real estate, crypto, gold, private businesses, and more. Learn the essential tax rules and strategies to cultivate your retirement growth.
In this episode, we chat about…
Introduction to Self-Directed IRAs: Explained what a self-directed IRA is and how it differs from traditional IRAs managed by custodians like Fidelity or Vanguard.
Three Things You Can’t Do with an IRA: Clear breakdown of IRS restrictions: no life insurance, no collectibles, and no self-dealing (IRC Section 4975(c)).
What Triggers UBIT (Unrelated Business Income Tax): Covered the three scenarios that may trigger UBIT and outlined strategies to avoid or minimize it.
Solo 401(k) vs. Self-Directed IRA: Compared the advantages of solo 401(k)s for the self-employed, including UBIT exemptions and higher contribution limits.
Using an IRA LLC or "Checkbook IRA": Describe the structure, benefits of control, limited liability, and privacy offered by IRA LLCs.
Real Estate and Crypto with a Self-Directed IRA: Detailed how self-directed IRAs can be used for real estate and crypto investments, including the role of non-recourse loans.
Key Takeaways:
Self-directed IRAs allow you to invest in a wide range of alternative assets, with only a few IRS restrictions.
A qualified custodian is required to handle IRA funds and facilitate compliant investments.
UBIT may apply to leveraged real estate or active business investments, but it can often be reduced or avoided with the right strategy.
IRA LLCs with checkbook control offer more flexibility, privacy, and direct access to manage investments.
Solo 401(k)s are ideal for self-employed individuals, offering higher contribution limits and exemptions from UBIT on leveraged real estate.
Learning from credible sources and consulting professionals is essential to avoid costly mistakes in self-directed retirement planning
Resources from Adam
Resources from Mike and Nichole
+ Read the transcript
Mike: Hey, everybody. Welcome back to another episode of The Richer Geek Podcast. Today, we have Adam Bergman. He's a nine time author, former tax, and I'm gonna get this wrong, ERISA, ERISA attorney and the founder of IRA Financial, the industry level on self-directed retirement solutions. As a founder of IRA Financial, he's helped over 25,000 clients take control over the retirement funds and invest over $4.6 billion into alternative assets, including real estate, crypto, gold, private businesses, et cetera. How are you doing, Adam?
Adam: Great. Thanks so much for having me, Mike. Awesome. Mike: Absolutely. So give us the short version of who you are and how you got in this business. I don't need to know where you went to kindergarten and all that sort of stuff, but yeah. Who is Adam?
Adam: Yeah, it's a super interesting story. I was a tax lawyer in New York City for about eight years at some of the largest law firms in the world. I have a master's in tax law and I had never, ever, ever heard of a self-directed IRA. I just thought you were only allowed to buy stocks with your retirement account. I had a client who was a big hedge fund client in New York, and the partner asked me to look at whether he could use his IRA to invest in his hedge fund. And I was just blown away by this industry. I could not believe that you were able to do it, and my thinking was, hey, if I'm a pretty smart guy, I have a tax degree, a master's in tax law, I worked at some of the largest law firms in the world, if I never heard of this stuff, then there must be millions of Americans out there that would love to that efficiently use their retirement funds to invest in alternative assets. If they just were educated and knew it was an option, they would at least have the freedom to make that decision.
Mike: Everybody knows what their IRA is. It takes some, you know, out of my paycheck every month, but self-directed. What does that mean? That means I can just grab it myself and do what I want, how's it work?
Adam: Okay, so it's a great question. When IRAs were created in 1974 by ERISA. The Congress, the IRS, and the tax code did not distinguish between IRAs that invested in stocks and IRAs that did non-traditional investments. So there's only three things you can't do in an IRA. That's it. Okay? Under Section 408, you can't buy life insurance, can't buy collectibles like artwork. And then thirdly, under Internal Revenue Code Section 4975(c), you can't do any transaction that in any way, directly or indirectly personally benefits you, your lineal descendants, your parents, your children, your spouse, daughter and son-in-law, or any entities, 50% controlled by such person. So that means you can't buy a house and live in it, right? You can't take your IRA, take your family to Disney, take your IRA, buy yourself a Rolex watch. Otherwise you can do it, whether it's private equity, hedge funds, real estate, hard money loans, gold Bitcoin, so on and so forth. As long as you don't violate those three categories of investments you can do it. So there's really no distinction between an IRA you invest in TD or Schwab or Fidelity or Vanguard or a self-directed at IRA Financial. The only difference is we unlock your retirement account. We are an open architecture platform. You have the freedom to make those investments. We don't sell products. All we do is we get paid a flat fee for administering and custody in your IRA. That's it.
Mike: It is true that you have to use a custodian. You can't touch the money, right? A lot of people say, well, can I just put in my checking account and then wait, and then I'm just gonna invest it in whatever I want when I see it. You have to use a custodian, correct?
Adam: Great question. So, yes, by law, three types of institutions could be a custodian: a bank, a financial institution or a state charter trust company like IRA Financial. So that means if you have your money in an IRA Fidelity and you wanna buy real estate. If you just pulled it out of Fidelity, after 60 days, that would be a taxable distribution, and if you were under 59 1⁄2, there would also be a 10% additional tax. So what you have to do is you have to move the money tax-free from Fidelity, which is a custodian, to a self-directed custodian like IRA Financial Trust. It's a tax-free transfer. Then from IRA Financial Trust, we will then initiate your investment into real estate or private equity or Bitcoin So yes, you're right. You need that custodian as a bridge to make the investment because without that bridge, after 60 days, it becomes a taxable event.
Mike: And each distribution, let's say that, ladies and gentlemen, all of you know that I do hotel syndications. One of my clients uses Adam, one of my potential investors. They invest in one of the hotels. I give out distributions, 100% of that has to stay in that IRA, correct?
Adam: That is correct because the IRA's the owner, just like if Adam owns a hundred percent of a restaurant and there's a distribution for the restaurant, it would go to Adam, the owner. So in the case of your hotel syndication, everything I assume goes pro-rata. If my IRA owned 1% of the hotel and there was a million dollars of net distribution funds available, my IRA would get 1% of those funds. And generally in most cases they would be tax-free.
Mike: I've heard some rumors, some things people say like, there's this tax on those distributions and you know, there's something in there that they said that. You should not do self-directed IRAs because they're still taxed, even though they're not touching it.
Adam: They're partly wrong. Here's the truth. As a tax attorney, this is the law. Yeah. So in 95% of the cases, when you make an investment with your IRA, it will return back to your IRA tax-free. That's known as deferral. It's known as compounded returns. If you have a Roth IRA, so long as you're over 59½ and the Roth's been open five years. You can then pull the money out of the Roth IRA and live off those funds tax-free. But let's stay in the IRA world, so if your IRA generates capital gains, interest, dividends, royalties, or rental income, the funds will come back through the IRA tax-free. No tax. If Adam invested $50 in Bitcoin and it went up to $50 million and I bought it in my IRA. When I sold the Bitcoin for $50 million, it would go back to my IRA tax-free. It's a capital gain transaction. Just like if I got dividends from a stock interest from a hard money loan, or if I bought and sold real estate. Now, there's this ugly four-letter wallet word called UBIT, Unrelated Business Income Tax, okay? So UBIT only attacks a very, very minuscule amount of retirement transactions. It's only in these three specific cases. One, if you use margin to buy stock. It has to be a non-recourse because you're not allowed to personally guarantee your IRA's obligation, unfortunately. Yeah, that's just a rule in the tax code. If you use margin to buy stock and you made money, there potentially could be a UBIT tax. And the tax rate follows the trust tax rates, which are relatively high, they can go all the way up to 37%, if you have about $15,000 in net income. But if your investment generates less than a thousand bucks or has losses, obviously there's no tax and the losses could be used to offset future income. That's the first way to trigger UBIT. The second is, if you use non-recourse loans for real estate, okay? I have $50,000 in my IRA, I borrow $50,000 from a bank non-recourse, meaning I don't personally guarantee it. So I have a hundred grand. I bought a piece of property. I sell it for 250% of my gain, which relates to the debt to equity ratio. 50 and 50 would be subject to this UBIT tax. There's a workaround there. I can set you up with a 401(k) if you're self-employed, and there's an exception from UBIT on real estate in a 401(k). And then the third and most common way to trigger UBIT is if you invest a retirement account in an IRA or 401(k) in an active business, like a hotel, like a restaurant, like a software company, and that venture is in an LLC or a pass through entity. There could be UBIT on the business income, right? So that's your point. Let's say you have a restaurant and your IRA owns 50% of it and it generates $100,000 in net profits. My IRA potentially could pay tax on that 50% of the allocation. More sophisticated funds use offshore feeders, which can get you around the UBIT depending on the investment. I can restructure the investment in different ways, which is what we do with our clients, who are trying to do more sophisticated investments that could trigger UBIT. We would get into a scenario with them and on a case by case basis, work out a structure that minimizes tax. To answer your question, going full circle, sorry to be so Yeah, it's okay. Long-winded, that's what lawyers do. In most cases there's no tax. Okay? It's generally if you use real estate with leverage in an IRA or if you invest in an active trader business in a pass-through entity like an LLC, that's why if your IRA owns Apple Stock or Tesla or Alphabet, there's no UBIT, right? Because tho, 99% of all publicly traded stocks, if not almost a hundred percent now, or C-corp. A C-corp blocks the UBIT, right? Why? Because a C-corp pays 21% entity tax, so there's no reason to have a UBIT tax. It's only imposed on a pass-through LLC, where LLCs do not have an entity level tax, right? There's only a member shareholder level. So that's why this ugly four-letter word tax comes in. The good news is there's ways to get around it and there's ways to minimize it. If you work with the right people.
Mike: Well, there you go. Now I know, because I've had some investors say, "No, there's that UBIT thing, and I'd like to go, " I'm a hotel guy. I'm not an attorney. I mean, I don't know, so thank you for that. Now, you did say invest in a hotel that has leverage. What if I'm buying a hotel for cash and there's someone that has a self-directed IRA? There's no leverage.
Adam: Right, because no leverage. That's great, but you still have that business income because the IRS would treat a hotel, unlike an apartment complex that's deemed rental real estate under the treasury regulations, a hotel, because of the service provided to the hotel guests, it's treated as a business instead of a passive. So if instead of a hotel, let's say, you invested in an apartment complex, that would be no leverage, there's no tax on any rental income or capital gains on the sale. But a hotel, because of the level of service provided, the IRS treats that as a business. So there would potentially be UBIT tax on distributions, even if there's no leverage in the United States, there's potentially workarounds offshore. But again, I can set you up with a C-corp blocker. I can reduce the tax to 21% also for real estate and hotel operations because of accelerated depreciation and a lot of losses in the first several years of the investment, those losses could be used to offset future incomes. So from a net-net standpoint, I've been doing this for over 15 years. I've seen it where in a lot of cases, the losses at the front end of the investment will offset most of the gains on the backend.
Mike: There we go. Ladies and gentlemen, again, Adam Bergman, he's talking everything about self-directed IRAs, and we're gonna continue down those lanes. So can I roll over any other type of retirement accounts. Let's say that, I've got some in the IRAs, but I don't have a lot, but I've got all these other different things. Can I shift different funds around into a self-directed IRA or does it always have to be an IRA that gets self-directed?
Adam: Yeah, so another great question. This is how you can fund a self-directed IRA. Number one, contributions. 2025, you can still actually do, if you're listening to this podcast or watching this before April 15th, 2025, you can still make $7,000 contributions, for 2024 in 2025. If you passed April 15, 2025, then you could still make $7,000 or $8,000 if you're over 50, for 25 years. So that's the first way to fund an IRA is you can always make contributions. If you make too much income, you may have limitations on how much you can deduct, but you can also always do a Roth IRA through what's called a Backdoor Roth IRA. Even if you make more than $240,000 a year, you could still potentially do a Roth, so that's always an option. Number two, rollover or transfer. So if you have an IRA at Vanguard, Fidelity or traditional IRA or a Roth IRA, you can always move that to IRA Financial if you want to do alternative assets tax-free. If you have a 401(k) at work, okay? Do you have access to those funds? So here's the interesting thing with 401(k)s, which a lot of people don't realize. It's actually not your money until you leave the job or you turn 59½. If you are, let's say, working at Tesla or Apple and you're 45 years old, you have a million dollars in your 401(k). Unless you leave your job, that money has to stay in the 401(k). You cannot roll it to a self-directed IRA or even any IRA because there's a planned trigger and event rule. IRAs don't have trigger and event rules. So if you leave your job at Apple because you want to go work at Google, you have a trigger and event rule, and then you can now move the fund's tax rate, a rollover from your employer, 401(k) to an IRA. Just the same way, if you reach the age of 59½, the only way to use non-retirement money in an IRA is through a contribution. So if you have a billion dollars in a bank account somewhere. And you want to open a self-directed IRA, and unfortunately you just never had time to save. Unfortunately, all you can put in is $7,000-$8,000 if you're over 50. But if you have other retirement accounts like a 401(k), even a 457(b), or 403(b), government plans, SEP IRA, SIMPLE IRA, or Roth IRA. You could then roll those into a self-directed IRA to do investing. We also do health savings accounts that could be self-directed or Coverdells, not 529 plans, but Coverdell for education. Those could also be invested in alternative assets.
Mike: See, everybody? I don't know. My head starts going, you know, and that's why we leave it to the experts and why we don't do this ourselves with Adam. There's all these lawyers, attorneys, especially the government, they love these acronyms, synonyms, and all the other mss and you know, we talked about UBIT, then there's UBTI and then there's UDF. It's all just different words saying the same thing.
Adam: Yeah. So Unrelated Business Income Taxes (UBIT), (UBTI) Unrelated Business Taxable Income, same thing. Okay. And then UDFI is Unrelated Debt Finance Income, which triggers a UBTI. So to keep things simple, just remember, if you do these three things, if you invest in an IRA that uses leverage to buy stock. Yep. Uses an IRA to leverage to buy real estate. There's an exception for 401(k)s or use an IRA or 401(k) to invest in a business through a pass-through like an LLC, you could trigger UBIT, whether you call it UDFI, UBIT, UBTI, it's the same, 37% maximum tax.
Mike: Yeah. There you go. Now let's get into something else. Some people will talk about Checkbook IRA. If I am self-directed, do I get a checkbook? Or what is a Checkbook IRA or you know, an IRA LLC type of a thing. Adam: I was one of the first companies to work in the self-directed IRA ILLC space. I've actually written two books just on the IRA LLC. So there's two ways you can use a self-directed IRA, there's what's called the full-service or custodian approach. And here's an example, right? Adam has $100,000 on Fidelity and I wanna buy a piece of raw land, okay? Fidelity is not gonna let me buy the raw land. I opened an account at IRA Financial. I rolled a hundred thousand dollars tax-free from Fidelity to IRA Financial. And then I tell IRA Financial, "Hey, IRA Financial, invest my $100,000 in that raw piece of land." And then title to the land would be IRA financial trust company for the benefit of Adam Bergman's IRA. That's a full-service or custodian IRA, that's probably the most popular over the last 10 or so years, the whole concept of checkbook control LLC has become more popular. For a number of reasons. Number one, people want an LLC because they want limited liability protection, especially if they're doing real estate.
Mike: Yep.
Adam: Number two, they want privacy. Some folks don't want people to know they're using an IRA to make an investment. So what they do is instead of having the IRA Financial custodian by the land, IRA Financial will set up an LLC, special purpose LLC. Call it whatever you want now, XYZ LLC, so long as the name is available. We'll generally set it up in the state you want, but most people will set it up where the asset will be located, the real estate, for example, and we'll provide you the EI and the opera agreement and the checkbook control comes from because you as the manager, the IRA will be the owner, you'll manage it, right? Giving you what's called checkbook control. So you can send a wire, you can write a check, you can do a Venmo or whatever. If you need to pay a contractor, right? You need to pay a plumber, you pay a landscaper, you gotta pay taxes, you gotta hire an accountant, lawyer, whatever. It's much easier to do it as the manager of the LLC, because you can write the check versus going on my app, going IRA Financial indicating where you want us to send $1,000 to pay Joe the plumber. And it takes more time and more friction, more complexity for no reason. You can get the LLC, you have more control, you have the privacy, and you have the checkbook control lLC, limited liability protection. For a lot of real estate investors and investors that want more privacy, it's a small price to pay. It's a small one time establishment fee. And that's it. It's the same fee, going forward. For other folks who are just like, Hey, I'm investing in a private equity fund. I don't care if people know it's an IRA that owns it, or I'm buying a raw piece of land. There's not a lot of activity. I don't need to involve the custodian very much. I don't need to spend the money up front. I don't care about limited liability protection. It's cool. There's no right or wrong. Both are great solutions. It's what works for you.
Mike: Yeah, that's a very good explanation. Everybody, again, Adam Bergman. Some people say, well, maybe I don't have enough, you know, to cover fees, What are you seeing? Is there a minimum of like, Hey, unless you have $50,000 and you're self-directed, don't do things, you know, what would you probably tell people?
Adam: With cryptos, it's different, right? We've opened a lot of accounts lately where people put in $2,000, $1,000 because our crypto account is basically like $100 a year. It's cheap. Other than that, there's really no cost. But yeah, generally, as you know, doing private equity, there's not a lot to buy for less than $25,000. So most of our clients will have more than 25K, but with crypto's been the one asset class that has expanded the client base 'cause there are people that just wanna get exposure to some coins and they'll put a $1,000, $2,000, $3,000. But for more of our traditional term alternative asset investors that are doing private equity real estate and gold. Gold, people will get in for $10,000+, generally. We have flat fees. It's what, $400 a year? So it's not super expensive to maintain the account. We don't charge asset valuation fees. So as your investments and account goes up in value, you don't have to pay us more. But I would say, the $25,000+ is kind of the sweet spot where we see most of our clients.
Mike: Yeah. And that is very important, ladies and gentlemen, is the valuation fees. It's like, man, I just paid one of those. No. And if I had gone with that, I wouldn't have had to pay that. So it's you who live and learn.
Adam: Because you're doing the work. It's self-directed. You're filling out the form, you're doing all the work. Why should I make more money? I get it. If you're a financial advisor and you're telling me, Hey, buy this fund A versus fund B, fine. But no, I don't believe that we keep our fees low, and we want people to have the freedom to invest in what they want.
Mike: That's right. A couple last questions. Those people just like, no, I don't do the self-directed and it's probably 'cause they don't know anything about it, but I have a solo 401(k), should I use that?and what are the differences between those two?
Adam: Solo 401(k) is great, I wrote two books on those. It's basically a mini 401(k) for someone who's self-employed. If you're self-employed, you have a business with no full-time employees, that means a 1,000 hours or more or two consecutive years of 500 hours or more. Spouses don't count as employees. So you and your spouse can still open a solo You can set up your own little mini, solo 401(k). Which is great because you can be the trustee in our plan. Unlike Fidelity or Vanguard, it has checkbook control giving you as the trustee the ability to make alternative asset investments, without an LLC, you don't even need it 'cause you're the trustee. You can put away a lot more money than an IRA. $70,000+ in 2025.
Mike: Yeah.
Adam: You can borrow up to $50,000 against your money tax-free. You can do what's something called a mega backdoor Roth where you can put away $70,000, dollar for dollar. All in Roth. You got great asset and credit protection and if you wanna buy real estate and use a non-recourse loan for leverage, you don't pay that UBIT tax because there's an exception under 514(c)(9) of the code against UBIT for 401(k). So for my real estate investors. I try to get them all into solo 401(k)s if they're self-employed and they satisfy those rules because they love the exemption from UBIT and the flexibility. So it's kind of an IRA, it's just a more robust IRA because you have more features, but it gives you the same alternative asset powers as a self-directed IRA.
Mike: Yeah. And it's so true. Ladies and gentlemen, if you have your own business, you know, like I do, and I don't know how many decades I went without doing any of this stuff. I just put money in a savings account that gave me 0.00002%. And it wasn't until I had a CFO that said, "Mike, I can save you $180,000 just this year by opening this and this and, backdoor, this and all these different things." And I was like, "Oh my goodness, man. It's like, okay. Well, better late than never, I guess." But late ladies and gentlemen, if you are self-employed, and I know a lot of you are thinking about this stuff, because Adam will set you up on these things and you won't leave. It doesn't cost that much to set these things up, but just the tax savings, instead of me getting give, giving myself all these salaries. I could be putting, you know, all this money away in, in the tax deferred accounts, and it was just absolutely amazing. Now, Adam, when we click on irafinancial.com, and I know some of our listeners will, what will they find? How can they get some educational materials? What's on the website?
Adam: So you can go to IRA Financial, irafinancialgroup.com, irafinancialtrust.com. Like there's lots of stuff. I've written nine books. You can look for them on Amazon, you can go on YouTube. There's just lots of information. I would just make sure you know who you're getting it from because unfortunately there's a lot of these so-called experts online, but you know, this is a tax area. Just like I don't pull my own teeth. I'm not a dentist like I went to law school. I have a master's in tax law and unfortunately I deal with a lot of clients that get bad advice and they come to me and they never are spoken to about UBIT or other issues and they get into jams. Make sure you look at who's providing the info, and speak to the right people. You can do a lot on your own. There's a lot of great data out there. and ultimately, like you see, the American flag behind you, Mike, like there's nothing more American I think than taking control of your future, there's no guarantee social security will be here. Forget about 30 years. How about in like 8 to 10 years? It's supposed to run out in the next seven years, okay? So the government doesn't provide us, other than Social Security, we're on our own. So the way to do it is whether it's an IRA, 401(k), we have to educate ourselves because unfortunately, our schools do not educate us. Retirement saving. Like I went, obviously I went to college, I went to law school. I have a master's in tax law. I never even knew about this stuff. So we're failing ourselves. Unfortunately it's up to you and if you're listening to this, you're smart enough to realize that if you understand compound and returns and you do these three things, this is all. I'll end with these three simple things: You start as early as you can make a contribution, whether it's an IRA or 401(k). If you are at a job that gives you. A 401(k) put in as much as you can because they're probably giving you at least a 3% safe harbor match. So it's free money. Number two, be consistent. Just try, even if you have a tough year, put $100 away, $50, $1,000. Just keep your habits. And third, trust the process. The compounding returns. The longer you let your money flow. The more it's gonna grow. If you look at the SP500, less than a hundred years, it's over 10%. You add alternative assets in there, you should be getting 13% to 16% on an annual basis, and we all could be seven figure tax-free millionaires. We just need to take our time and be patient.
Mike: Yeah, there you go. And everybody, this is one of the reasons why I love having my podcast. Why I created The Richer Geek is to have Adam on people like Adam to give us the education, give us the knowledge so that we don't make those mistakes. So listen to this podcast. I know a lot of you're gonna be taking notes. Go to his website and Adam, where else can people find you?
Adam: Yeah, don't call me at three in the morning. Just IRA Financial, irafinancialgroup.com, irafinancial.com, IRA Financial Trust. You can just Google IRA Financial. There's so much info. You can Google self-directed IRAs. There's great videos. You can go to IRA Financial, YouTube channel. There's a lot of great content. It's all free. And you can just play around, ask questions. That's the most important thing. Be curious. This is how rich people get rich, I'm telling you. You can Google Peter Thiel if you wanna learn. He is the smartest investor. He has about $4 billion in a Roth IRA. Meaning he's, I think he's around 57 in two years, he'll be able to pull that money out tax-free. and he's kind of a mentor. So there's opportunities, and I've seen it with my client base. I've seen people turn $5,000 into $10 million. I've seen people turn $5,000 into $6 million. It happens. You obviously need to know what you're doing but if you can do it and hit a home run, why not do it in a tax efficient account and shelter all the gains from taxation.
Mike: Absolutely. And this is why we trust professionals like Adam. Adam, thank you so much for coming on The Richer Geek. Have a wonderful night.
Adam: Thanks, Mike. Pleasure.
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ABOUT ADAM BERGMAN
Adam Bergman is the founder and CEO of IRA Financial Group and IRA Financial Trust, a custodian and financial technology leader in self-directed retirement plans. Together, they are the market's fastest growing providers in this space, helping over 17,000 clients invest $4.6 billion in alternative assets.
He also owns two pension administration firms and is the author of 7 books on self-directed retirement plans. A leading voice in the industry, Adam is a contributor to Forbes.com and a member of the Forbes Finance Council. He has been featured on CBS News and quoted in 130+ major publications including Businessweek, CNN Money, Forbes, Bloomberg, USA Today, and American Lawyer.
Previously, Adam was a tax and ERISA attorney at White & Case LLP, Dewey LeBoeuf LLP, and Thelen LLP. He earned his B.A. from McGill University, J.D. (cum laude) from Syracuse University, and LL.M. in Taxation from NYU School of Law. He is a member of the Tax Division of the ABA and NY State Bar.