Tax Attorney Needed to Evaluate LP Group Structure & Disregarded Entity Status

Project Description: We are seeking an experienced U.S. tax attorney to evaluate a multi-entity ownership structure and provide legal tax advice regarding entity classification. Background / Structure Overview: The group consists of eight (8) Limited Partnerships (LPs). Each LP is owned: A. 99% by an individual, and B. 1% by an LLC. The LLC is owned by a revocable trust. The grantor of the revocable trust is the same individual who owns the 99% interest in each LP. Scope of Work: 1. Review the ownership and control structure of the LPs. 2. Analyze the federal tax treatment of the entities under U.S. tax law. 3. Provide a legal opinion/advice on whether the LPs may be treated as disregarded entities for tax purposes, considering: A. Grantor trust rules B. Partnership tax regulations C. Substance-over-form considerations (if applicable) 4. Identify any risks, caveats, or compliance considerations. 5. (Optional but preferred) Suggest alternative structuring if the current setup poses tax or legal issues. Deliverables: 1. Written legal analysis and conclusion (memo or opinion-style summary is acceptable). 2. Clear explanation suitable for accountants and business owners. 3. Citations to relevant IRS regulations or authorities where appropriate. Ideal Candidate: Licensed U.S. tax attorney (LL.M. in Tax is a plus). Strong experience with: Partnership taxation Disregarded entities Grantor trusts Complex entity structures Prior experience advising closely held businesses or family structures preferred. Project Type: One-time legal advisory project (with potential for follow-on work) To Apply, Please Include: Brief summary of relevant experience. Confirmation of U.S. bar admission. Examples of similar tax-structure analyses (high level; no confidential details). Apply tot his job