Job Description
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.
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