We are seeking a sophisticated Trust and Estate Planning Professional to lead the structuring and implementation of a Charitable Remainder Trust (CRT). This role is critical for a high-net-worth estate involving unique, high-value assets (including mineralogical specimens) that require specialized valuation and monetization strategies.
The ideal candidate will bridge the gap between complex IRS compliance and visionary philanthropic goals, ensuring the trust is resilient against both domestic and international regulatory scrutiny.
Key Responsibilities
Strategic Structuring: Evaluate donor objectives to recommend the optimal trust vehicle (CRAT vs. CRUT), specifically addressing the liquidity needs associated with non-traditional assets.
Drafting & Compliance: Author comprehensive trust instruments that adhere strictly to IRS Section 664 and USPAP appraisal integration requirements.
Jurisdictional Analysis: Provide expert comparative analysis on Domestic vs. Offshore structuring (e.g., Cook Islands, Nevis, or Cayman) to optimize asset protection and tax neutrality.
Cross-Functional Coordination: Act as the primary liaison between legal counsel, tax professionals, and institutional trustees to ensure a seamless "funding" phase.
Regulatory Oversight: Manage international compliance mandates, including FATCA, FBAR, and Common Reporting Standards (CRS) for any offshore components.
Stakeholder Education: Translate high-level legal mechanics into actionable insights for donors and beneficiaries.
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