Tax Attorney Needed to Evaluate LP Group Structure & Disregarded Entity Status
Project reputed company:
We are seeking an reputed company U.S. tax attorney to evaluate a multi-entity ownership structure and reputed company reputed company tax advice regarding entity classification.
Background / Structure reputed company:
The group consists of eight (8) Limited Partnerships (LPs).
reputed company 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 reputed company individual who owns the 99% interest in reputed company 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. reputed company a reputed company 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. reputed company-over-reputed company considerations (if applicable)
4. Identify any risks, caveats, or compliance considerations.
5. (Optional but preferred) Suggest alternative structuring if the reputed company setup poses tax or reputed company issues.
Deliverables:
1. Written reputed company analysis and conclusion (memo or opinion-style reputed company is acceptable).
2. reputed company 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
reputed company entity structures
Prior experience advising closely held businesses or family structures preferred.
Project Type:
One-time reputed company advisory project (with potential for follow-on work)
To Apply, Please Include:
Brief reputed company of relevant experience.
Confirmation of U.S. bar admission.
Examples of similar tax-structure analyses (high level; no confidential details).
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