Tax Opinion

(redirected from Tax Opinions)

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.
References in periodicals archive ?
Previously, she worked at PwC in the Tax Project Delivery Group and spent 10 years at KPMG where she was a member of the Washington National Tax Accounting Methods and Periods Group, responsible for quality assurance regarding federal tax accounting methods and periods, including drafting and reviewing tax opinions, technical memoranda, and IRS ruling requests.
35 provided detailed rules for tax opinions that qualified as "covered opinions.
Topics include errors on tax returns and during IRS examination and appeals, disclosing information to the IRS, disclosure of privileged information and waiver, paying fact witnesses during litigation, spoliation and duty to preserve evidence, candor before a tribunal and the IRS, backdating of documents, and levels of tax opinions.
35 provides detailed rules for tax opinions constituting "covered opinions," which include WTA concerning: a listed transaction: a transaction with the principal purpose of tax avoidance or evasion; or a transaction with a significant purpose of tax avoidance or evasion--if the WTA is: a reliance opinion: a marketed opinion: subject to confidentiality conditions or contractual protection.
The Tax Court's opinion is a stark reminder of the real function of professional tax opinions and tax advice: to help taxpayers properly comply with the tax law and pay the lowest amount of tax, not to insulate taxpayers from responsibility and aid them in avoiding taxes by advocating unreasonable and unsupportable positions.
With respect to tax opinions that support the tax accrual of an item, auditors generally adhere to a more stringent policy and request to review all such opinions.
8 are proposed to address new requirements that apply when providing certain types of tax opinions.
Circular 230 details the scope of tax opinions and other tax advice issued by attorneys and others who practice before the IRS.
These changes are expected to have little impact on federal tax revenue, but they will greatly enhance the ability of commercial real estate property owners to upgrade property and perform customary property management activities after the mortgage has been securitized, without the need for costly and burdensome tax opinions.
It is our expectation that these 32 issuers would not likely be subject to income taxes if they were to lose their QRS status, since tax opinions either have been furnished stating that the Cayman issuers would not be treated as foreign corporations deemed to be engaged in the conduct of a trade or business within the United States, or the transaction documents call for such opinion to be delivered if the Cayman issuers were to lose their QRS status.
Prior to working at Treasury, Mackay spent nearly 13 years with Deloitte Tax where he was responsible for quality assurance regarding federal tax accounting methods and periods, including drafting and reviewing tax opinions, technical memoranda, and IRS ruling requests.
The Tax Court denied a taxpayer's motion to compel the IRS to produce redacted copies of all third-party tax opinions regarding son-of-boss transactions it had collected, as well as a list of the names and addresses of all law firms and accounting firms known to the IRS to have issued tax opinion letters regarding son-of-boss transactions because the opinion letters and the firm list were not relevant, the request did not appear reasonably calculated to lead to discovery of admissible evidence, and the materials were nondisclosable "return information" per Sec.