Tax Opinion

Tax Opinion

An official opinion by an attorney stating how an investment (especially a bond) should be treated for tax purposes. For example, in the case of a municipal bond, the issuer may hire an attorney to write a tax opinion detailing how it complies with requirements exempting the interest from taxation.
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Gopsill advised the Worldwide Yacht Brokers Association, providing a tax opinion regarding a landmark proposal by a leading yacht broker in France.
Scripps has received this tax opinion, which concludes that the sale of Journal Media Group will not result in the prior Scripps spinoff becoming taxable to Scripps or its shareholders.
deliver a tax opinion that will be readily accepted by the investor marketplace, then the other co-counsel firm(s) would take on that responsibility
Wiener, who happens to be an investor in two Ginn properties, has written tax opinion letters for several owners challenging the propriety of the 1099 and taking the position that it is neither income to the taxpayer nor deductible to the lender.
Coverages offered will include: Property, General Casualty, Environmental Liability, Employers Liability & Workers Compensation, Accident and Health, Motor, Professional and Management Liability, Representations and Warranties, Contingency, Credit & Surety, Burglary & Theft, Political Risks, Fidelity and Crime, Agriculture, Engineering, Cyber and Technology, Advertising and Media Liability, Tax Opinion and Loss Mitigation, Sabotage and Terrorism, Aviation, and Marine products.
initial public offering, Goodwin Procter helped to create the first public UPREIT structure by providing the first UPREIT tax opinion used in a public securities offering.
However, the company made it clear to the investment bank and the accounting firm that the asset transfer and special distribution had to be nontaxable and that it required a "should" tax opinion letter (the highest level of assurance that a position will succeed on the merits) from the accounting firm regarding the tax results of the transaction.
The product of Henry's efforts was the tax opinion which made possible the implementation of IOTA in Florida, and the implementation of comparable programs (called IOLTA) in 49 other states and the District of Columbia.
5 The tax opinion might not be required if the sale of the shares is exempted under one of the numerous tax treaties Mexico has entered into with various countries, provided a seller's representative is appointed.
Under current rules, a tax opinion must be obtained before demolition/tenant improvements begin.
In Writing Legal Opinion Letters for Tax Lawyers provides tax lawyers with tips, tricks and guidance on how to navigate the stringent legal regulations, sensitive client issues, and very-real potential for legal exposure surrounding tax opinion letters.