Opinion Letter - Tax Lawyer
Description:
I am seeking an experienced U.S. tax attorney with expertise in high-net-worth tax strategies. The purpose of this project is to obtain a formal legal opinion letter on a company letterhead specific charitable structure we are implementing, known as the Strategic Giving Partnership.
Scope of Work:
Review the proposed structure, which involves:
A high-net-worth business owner is funding a multi-member LLC.
The LLC structured with a major public charity as a 99% limited partner and the business owner retaining 1% as the managing member.
The goal of achieving significant tax savings while maintaining compliance with IRS regulations.
Analyze potential issues including (but not limited to):
Self-dealing rules
Disqualified person status
Excess benefit transactions
Compliance differences between public charities, donor-advised funds, and private foundations
Provide a written legal opinion letter confirming the compliance and defensibility of the structure.
Cite relevant IRS codes, regulations, and precedents.
Requirements:
Licensed U.S. tax attorney in good standing.
Minimum 10 years of experience in charitable planning, private foundations, supporting organizations, or donor-advised funds.
Strong knowledge of IRS compliance regarding charitable partnerships.
Ability to deliver a professional opinion letter suitable for presentation to CPAs, financial advisors, and clients.
Preferred Experience:
Prior work with family offices or high-net-worth individuals.
Familiarity with charitable freeze techniques, advanced LLC structuring, and IRS case law (e.g., Petter, Christiansen).
Deliverables:
Legal opinion letter (PDF) confirming the compliance of the Strategic Giving Partnership structure with IRS regulations.
Citations of relevant IRS code sections and applicable rulings or case law.
Apply tot his job
Apply To this Job
I am seeking an experienced U.S. tax attorney with expertise in high-net-worth tax strategies. The purpose of this project is to obtain a formal legal opinion letter on a company letterhead specific charitable structure we are implementing, known as the Strategic Giving Partnership.
Scope of Work:
Review the proposed structure, which involves:
A high-net-worth business owner is funding a multi-member LLC.
The LLC structured with a major public charity as a 99% limited partner and the business owner retaining 1% as the managing member.
The goal of achieving significant tax savings while maintaining compliance with IRS regulations.
Analyze potential issues including (but not limited to):
Self-dealing rules
Disqualified person status
Excess benefit transactions
Compliance differences between public charities, donor-advised funds, and private foundations
Provide a written legal opinion letter confirming the compliance and defensibility of the structure.
Cite relevant IRS codes, regulations, and precedents.
Requirements:
Licensed U.S. tax attorney in good standing.
Minimum 10 years of experience in charitable planning, private foundations, supporting organizations, or donor-advised funds.
Strong knowledge of IRS compliance regarding charitable partnerships.
Ability to deliver a professional opinion letter suitable for presentation to CPAs, financial advisors, and clients.
Preferred Experience:
Prior work with family offices or high-net-worth individuals.
Familiarity with charitable freeze techniques, advanced LLC structuring, and IRS case law (e.g., Petter, Christiansen).
Deliverables:
Legal opinion letter (PDF) confirming the compliance of the Strategic Giving Partnership structure with IRS regulations.
Citations of relevant IRS code sections and applicable rulings or case law.
Apply tot his job
Apply To this Job