Expert Tax Attorney / Trust & Estate Architect: Pre-Exit QSBS Stacking Strategy (Section 1202)

Overview: I am the founder of a high-growth, venture-backed Delaware C-Corp in the deep tech/defense space. We are tracking toward a significant liquidity event ($150M–$250M exit scenario in the next 12+ Months) and possess shares that I believe cleanly qualify for Section 1202 Qualified Small Business Stock (QSBS) treatment. Because our potential exit valuation far exceeds the baseline $10M federal exclusion cap, I am looking to bring on an elite tax strategist/trust architect to design and execute a QSBS Stacking Strategy using irrevocable non-grantor trusts before we sign an LOI or definitive acquisition agreement. This is a highly specialized, pre-exit structural planning role. Please do not apply if you are a general corporate accountant or a standard retail CPA. I need a master of Section 1202 and advanced wealth preservation. Key Deliverables & Scope of Work: Trust Architecture Blueprint: - Design the optimal structure for multiple irrevocable non-grantor trusts (e.g., SLATs, incomplete gift trusts, or zero-state resident trusts) to cleanly establish them as separate taxpayers under § 1202(b)(1). -Clawback & Control Planning: Structure the trust provisions so that I can maximize the tax exclusion while maintaining compliance with non-grantor rules (navigating sections 671-679). - Assignment of Income Safeguards: Audit our current corporate timelines to ensure the gifting and share transfers are completed safely ahead of any "binding commitment" to avoid IRS step-transaction or assignment-of-income challenges. - State-Level Risk Mitigation: Advise on state-specific tax exposure and compliance, specifically regarding state decoupling risks (e.g., navigating New York State/NYC vs. Florida residency implications). Required Qualifications: - LL.M. in Taxation, JD with an elite tax/estate focus, or a specialized CPA/PFS with documented experience structuralizing $50M+ tech exits. -Deep, authoritative expertise in Section 1202 (QSBS) and Section 1045 (QSBS Rollovers). -Proven track record of successfully executing trust-stacking strategies that have survived audit scrutiny. -Flawless understanding of the boundary between grantor and non-grantor trust status.