Tax Opinions and IRS Rulings

    We write a large volume of tax opinions on a wide variety of federal, state, and international tax matters.  Subjects may be whether a payment is income, proceeds are capital gain, a payment is subject to withholding or Form 1099 reporting, a transaction is taxable to one taxpayer or another, etc.& We have written tax opinions on corporate and real estate transactions, tax-exempt organizations, residency and domicile, charitable contributions, hedge and investment fund issues, and more. 

    We also regularly go before the IRS for formal rulings. These articles help explain the uses of tax opinions, opinion standards, and IRS private letter ruling procedures: