Common use of Tax Opinion Letters Clause in Contracts

Tax Opinion Letters. Any statement related to taxes contained in any communication must be considered as preliminary only and may not be relied upon in any tax planning unless it is clearly designated as a formal opinion. Only a formal opinion letter that reviews ALL facts and discloses ALL potential issues can be treated as “formal” tax advice on which the client may rely for purposes of avoiding certain tax penalties. Should one desire a formal opinion on a particular tax matter for the purpose of avoiding the imposition of any penalties, our firm must be engaged for that specific purpose; and we shall at that time discuss further the Treasury requirements that must be met and whether it is possible to meet those requirements in the circumstances, as well as the anticipated time and fees involved.

Tax Opinion Letters. Any statement related to taxes contained in any communication must be considered as preliminary only and may not be relied upon in any tax planning unless it is clearly designated as a formal opinion. Only a formal opinion letter that reviews ALL facts and discloses ALL potential issues can be treated as “formal” tax advice on which the client may rely for purposes of avoiding certain tax penalties. Should one you desire a formal opinion on a particular tax matter for the purpose of avoiding the imposition of any penalties, our firm must be engaged for that specific purpose; and we shall at that time discuss further the Treasury requirements that must be met and whether it is possible to meet those requirements in the circumstances, as well as the anticipated time and fees involved.