Advanced Markets, Private Placement Life Insurance Attorney

This is a fully remote position, open to applicants in United States.

📋 Description

• Assess the suitability of clients and the economic aspects of private placement life insurance (PPLI), analyzing tax benefits in relation to associated charges, fees, and liquidity constraints.

• Advise on and document various ownership structures, including individual ownership, ILITs, trusts, and business planning arrangements.

• Examine insurance contracts, private placement memoranda, subscription agreements, investment management agreements, and disclosures.

• Verify life insurance qualification, conduct MEC testing, and ensure compliance with IRC §817(h) diversification and investor control under IRC §§ 72, 7702, and 7702A.

• Tackle issues related to private placements and securities, including determining accredited investor eligibility and identifying offering exemptions.

• Perform independent due diligence on carriers, policy charges, surrender terms, mortality assumptions, investment options, and assets held within policies.

• Evaluate advisers, compensation structures, conflicts of interest, and exit risks.

• Manage funding and policy issuance involving carriers, advisers, investment managers, trustees, CPAs, and fund managers.

• Create procedures for annual reviews, premium funding, and tax reporting.

• Develop a repository of PPLI trust language, structuring templates, and due diligence checklists.

• Provide training and mentorship to other attorneys at Hargrove on PPLI concepts.

• Expand PPLI and advanced market capabilities to other insurance channel partnerships.

• Collaborate with NetLaw and firm leadership on developing workflows and tools to enhance national planning scalability.

⛳️ Requirements

• Juris Doctor (J.D.) degree from an accredited law school.

• Active legal license in at least one U.S. jurisdiction.

• Extensive transactional experience with private placement life insurance (PPLI).

• In-depth knowledge of federal income tax implications of life insurance under IRC §§ 72, 7702, 7702A, and 817(h).

• Proven experience in structuring compliance for investor control and diversification.

• Background in advanced estate planning, including ILITs, dynasty trusts, premium gifting strategies, split-dollar arrangements, and estate liquidity planning.

• Understanding of private placement and securities issues, including accredited investor eligibility, offering exemptions, and subscription documents.

• Experience in executing due diligence on carriers and assessing policies and alternative investments within those policies.

• Capability to coordinate multidisciplinary transactions involving estate planning counsel, CPAs, investment advisors, insurance consultants, carriers, trustees, and fund managers.

• An LL.M. in Taxation is advantageous but secondary to practical PPLI transaction experience.

• Preferably a partner or senior counsel at a relevant private-client, tax, insurance products, or wealth planning practice, or from a carrier’s advanced planning department or a wirehouse wealth strategies team.

🏝️ Benefits

• Competitive salary and performance-based bonuses.

• Comprehensive health, dental, and vision insurance.

• Generous retirement savings plan with employer matching.

• Opportunities for professional development and continuing education.

• Flexible work environment and work-life balance initiatives.