Tax Opinion

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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 transaction is expected to close by end of the year, subject to customary closing conditions, including the approval of Altra shareholders, IRS tax ruling and applicable tax opinions, and regulatory approvals.
Under the MOA, BGLF will provide BOI with copies of all relevant local finance and memorandum circulars, local tax opinions and rulings, and real property tax opinions and rulings on all matters dealing with local treasury and assessment at the provincial, city, and municipality level.
Closing of the merger is subject to regulatory and stockholder approval, receipt of certain tax opinions and other customary closing conditions.
The final ratings will be assigned after RAM's satisfactory review of the finalised transaction documents and the relevant legal and tax opinions, and also after our validation of the assumptions employed in this transaction.
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.
The rating finalisation is dependent on further transaction details and the rating agency's review of the final pool, cash flow modeling, final structure, and legal and tax opinions.
WRITING HIGH-QUALITY TAX OPINIONS ON THE SUPREME COURT: PRE-JUDICIAL TAX EXPERTISE PREFERRED, BUT NOT REQUIRED
8 are proposed to address new requirements that apply when providing certain types of tax opinions.