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How do I write a tax opinion letter?

The letter should present the information in a straight-forward manner, clearly, concisely and completely. There is no room for ambiguity and the letter must address each of the elements of the transaction concerned. An effective tax opinion letter will discuss factual details as well as technical concerns.

What is reasonable basis in tax opinion?

[4] 31 C.F.R. 10.37(a)(3). [5] Reasonable basis is defined in (b)(3) of the regulations as follows: Reasonable basis is a relatively high standard of tax reporting, that is, docHubly higher than not frivolous or not patently improper.

How do I write a tax opinion letter?

The letter should present the information in a straight-forward manner, clearly, concisely and completely. There is no room for ambiguity and the letter must address each of the elements of the transaction concerned. An effective tax opinion letter will discuss factual details as well as technical concerns.

What is reasonable basis in tax opinion?

[4] 31 C.F.R. 10.37(a)(3). [5] Reasonable basis is defined in (b)(3) of the regulations as follows: Reasonable basis is a relatively high standard of tax reporting, that is, docHubly higher than not frivolous or not patently improper.

Can a CPA write a tax opinion?

Yes. When a matter is unclear or a client seeks tax advisement, his or her tax advisor (attorney, CPA, etc.) will often write an opinion letter for the client.

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What is the tax opinion standard more likely than not?

More likely than not (which is the standard that applies to a tax shelter or a reportable transaction to which Sec. 6662A applies) is defined as being of the reasonable belief that the position would more likely than not be sustained on its merits (Sec.

Can a CPA write a tax opinion?

Yes. When a matter is unclear or a client seeks tax advisement, his or her tax advisor (attorney, CPA, etc.) will often write an opinion letter for the client.

What is a written tax opinion?

A tax opinion can be about almost any tax issue. A good tax opinion discusses the facts, legal arguments, and pertinent authorities. One portion of the opinion says, it is our opinion that. But the vast majority of the opinion should analyze the facts and the law, presenting an even-handed assessment.

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What is the tax opinion standard more likely than not?

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