Posted Mar 12, 2026

Opinion Letter - Tax Lawyer

Apply Now
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.