Tax Opinions and IRS Rulings

    We write a large volume of tax opinions annually on a wide variety of federal, state, and international tax matters.  Subjects may be whether a settlement payment is income or is capital gain, if proceeds are subject to withholding or Form 1099 reporting, etc.  We write tax opinions on litigation finance, qualified small business stock (QSBS), residency and domicile, 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: