Trusts & Estates Attorney - Min 3-5 years experience
We are seeking an experienced Trusts & Estates Attorney with expertise in U.S. international tax matters, private placement life insurance (PPLI) structures, irrevocable trusts, and intentionally defective grantor trusts (IDGTs). The ideal candidate will have a background in sophisticated domestic and cross-border estate planning for high-net-worth individuals, families, and closely held businesses.
Key Responsibilities:
- Advise clients on complex domestic and international estate, gift, generation-skipping transfer (GST), and income tax planning strategies.
- Structure, implement, and administer irrevocable trusts, including IDGTs, grantor retained annuity trusts (GRATs), and foreign trusts.
- Design and implement private placement life insurance (PPLI) strategies for tax-efficient wealth transfer and asset protection.
- Provide guidance on pre-immigration and expatriation planning for non-U.S. citizens and U.S. persons relocating abroad.
- Counsel clients on U.S. tax reporting obligations for foreign trusts, foreign corporations, PFICs, and controlled foreign corporations (CFCs).
- Draft and review wills, revocable trusts, irrevocable trusts, gift agreements, and related estate planning documents.
- Collaborate with private client advisors, accountants, family offices, and investment managers to deliver integrated wealth planning solutions.
- Handle complex probate and trust administration matters, including cross-border estate settlements.
- Conduct research and prepare memoranda on U.S. federal and international estate, gift, and income tax issues.
- Monitor and advise on legislative changes affecting international private client planning.
Qualifications:
- Juris Doctor (JD) degree from an accredited law school.
- Admission to the Florida bar.
- Minimum 3-5 years of relevant experience in trusts and estates law with a focus on international tax and wealth planning.
- Deep understanding of Chapter 14 valuation rules, IRC Sections 671-679 (grantor trust rules), PFIC, FIRPTA, and FATCA implications.
- Experience structuring and analyzing PPLI and related insurance-based solutions.
- Familiarity with U.S. information reporting obligations (Forms 3520, 3520-A, 5471, 8865, 8938, BE-10/BE-12).
- Strong drafting, research, and analytical skills.
- Excellent written and oral communication skills.
- Ability to manage multiple projects independently and work collaboratively in a fast-paced environment.
- LL.M. in Taxation or Estate Planning is preferred but not required.
Preferred Skills:
- Fluent in a second language (e.g., Spanish, Portuguese) is a plus.
- Familiarity with asset protection strategies and offshore trust planning.
- Experience advising on qualified domestic trusts (QDOTs), pre-immigration gifting, and global mobility issues.
- Understanding of U.S. tax treaties and their impact on estate and gift tax planning.
Seniority level
Mid-Senior level
Employment type
Full-time
Industries
Legal Services