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).