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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The consummation of the Offer remains subject to various conditions, including the tender of at least a majority of the Shares outstanding immediately prior to the expiration of the Offer, redelivery of a tax opinion delivered at signing, and other customary conditions described in the Offer to Purchase filed by Sanofi with the U.
The closing of the transactions will be subject to various customary closing conditions, including regulatory approvals, receipt of a tax opinion, and the effectiveness of the registration statement with respect to USPS common shares being distributed to DXC shareholders.
Before employing it, however, Trump sought a formal tax opinion letter.
This is a point on which some clients may need professional tax opinion as there has been no detail given as to how this 50 per cent would be computed.
In some ways, Williams may find itself back to square one after the court ruling, which allows Energy Transfer to kill the merger after it failed to get lawyers to sign off on a tax opinion.
Gopsill advised the Worldwide Yacht Brokers Association, providing a tax opinion regarding a landmark proposal by a leading yacht broker in France.
In addition, he allegedly approved a false tax opinion letter, news reports said.
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.
It can reasonably be argued that a tax opinion from a reputable accounting or law firm that lays out all the relevant transaction facts, painstakingly addresses all of the relevant legal issues, and renders opinions on every issue is substantial, relative to the weight of authority supporting the contrary treatment.
The promoter of the transaction provided the taxpayer both a model tax opinion letter from the law firm of Brown & Wood LLP (Brown & Wood), and a tax opinion by Brown & Wood addressed to the taxpayer which was paid for by the promoter.
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.