Advanced Markets / Private Placement Life Insurance (PPLI) Attorney

Hargrove Online, PLLC d.b.a. Hargrove Firm is a national, client-focused estate planning law firm delivering sophisticated estate planning, tax planning, and wealth transfer solutions through the NetLaw platform. The firm works closely with financial advisors, wealth management teams, CPAs, insurance carriers, and families to help clients protect, manage, and transfer wealth, minimize tax exposure, and plan effectively for future generations. Position Overview The Advanced Markets / PPLI Attorney will serve as Hargrove Firm's independent tax and estate-planning authority on private placement life insurance, working closely with the firm's advanced-markets relationship with certain investment groups. This attorney will evaluate suitability and economics, design ownership and trust structures, review carrier and offering documentation, confirm tax compliance, and independently diligence the carriers, platforms, and advisers involved in each transaction. This role requires a seasoned attorney with direct, transactional PPLI experience — not a general life-insurance or estate-planning lawyer, and not someone whose role has primarily been product distribution or insurance sales. The attorney will also help build a reusable library of PPLI templates, train other Hargrove attorneys, and help extend this capability to insurance-channel partnerships beyond our current RIA relationships. Core Responsibilities PPLI Suitability, Structuring & Tax Compliance • Evaluate whether a client's investment profile, tax exposure, liquidity, insurability, and estate-planning objectives justify PPLI, and model projected tax savings against mortality charges, policy expenses, fees, and liquidity restrictions. • Recommend and document the appropriate ownership structure (individual, ILIT, other trust, or business-planning arrangement), coordinating with the client's existing estate-planning counsel and drawing on ILITs, dynasty trusts, premium-gifting, and split-dollar strategies as needed. • Review the insurance contract, private-placement memorandum, subscription agreement, investment-management agreement, and related disclosures; confirm life-insurance qualification, MEC testing, §817(h) diversification, and investor-control compliance under IRC §§ 72, 7702, and 7702A. • Address private-placement and securities issues, including accredited-investor eligibility, offering exemptions, and subscription documents, coordinating with broker-dealers or investment advisers as needed. Independent Diligence • Conduct independent diligence on carrier strength, policy charges, surrender provisions, mortality assumptions, investment options, and illustrations, including insurance-dedicated funds and other alternative or illiquid assets held within the policy. • Assess advisers, compensation arrangements, conflicts of interest, and exit risk, documenting diligence to a standard consistent with FINRA's expectations for private placements — approaching carrier and product claims with the scrutiny of independent counsel, not a distribution partner. Coordination, Compliance & Practice Development • Coordinate implementation through funding and policy issuance across the carrier, insurance adviser, investment manager, trustee, and CPA, and establish ongoing procedures for annual reviews, premium funding, and tax reporting. • Build a firm-owned library of PPLI trust language, structuring templates, and diligence checklists; train and mentor other Hargrove attorneys on core PPLI concepts to reduce key-person dependency. • Help the firm extend PPLI and advanced-markets capability to additional insurance-channel partnerships beyond M Financial, and work with NetLaw and firm leadership on workflows and tools to scale this planning nationally. Qualifications • J.D. from an accredited law school and active license to practice law in at least one U.S. jurisdiction; LL.M. in Taxation is helpful but secondary to actual, hands-on PPLI transaction experience. • Substantial experience in the federal income-tax treatment of life insurance (IRC §§ 72, 7702, 7702A, and 817(h)) and structuring investor-control and diversification compliance. • Experience with advanced estate planning — ILITs, dynasty trusts, premium-gifting strategies, split-dollar arrangements, and estate-liquidity planning. • Familiarity with private-placement and securities issues (accredited-investor eligibility, offering exemptions, subscription documents) and experience executing carrier due diligence, policies, and alternative investments held within a policy. • Demonstrated ability to coordinate multidisciplinary transactions across estate-planning counsel, CPAs, investment advisers, insurance consultants, carriers, trustees, and fund managers. • Ideally a partner or senior counsel at a firm with a recognized private client, tax, insurance-products, or wealth-planning practice, or from a carrier's advanced planning department or a wirehouse wealth strategies team. Core Competencies • PPLI Tax & Insurance Technical Mastery: — Substantial, transactional command of IRC §§ 72, 7702, 7702A, and 817(h) as applied to life insurance. • Investor-Control Rigor: — Structures investment authority so the policyholder is never treated as directly owning the underlying assets. • Advanced Estate-Planning Depth: — Fluent in ILITs, dynasty trusts, premium-gifting, split-dollar, and estate-liquidity planning, not just PPLI in isolation. • Product & Carrier Skepticism: — Independently diligences carriers, platforms, and products with the scrutiny of independent counsel, not a distribution partner. • Multidisciplinary Quarterbacking: — Coordinates smoothly across estate-planning counsel, CPAs, advisers, carriers, trustees, and fund managers without dropping handoffs. • Independence & Judgment: — Operates as independent legal counsel whose loyalty is to the client's suitability analysis, not to product distribution or sales. All job requirements in this job description indicate the minimum level of knowledge, skills, and abilities deemed necessary to perform the role competently. Employees may be required to perform other job-related assignments as requested by firm leadership.