Olb shall have received an opinion of ober kaler grimes shriver p c counsel to olb or a letter from rowles company llp olb s independent certified public accountants dated the closing date to the effect that the merger constitutes a reorganization under section 368 a of the irc. The letter should present the information in a straight forward manner clearly concisely and completely.
I do not prepare the tax returns of taxpayers who benefit from my tax advisory opinion letters 2 the purpose of the tax advisory opinion letter is to provide guidance to compliance oriented professionals as to how to address complex tax matters addressed in the opinion letter in their clients tax returns.
Tax opinion letter sample. I am a tax planner. An opinion letter is a tax attorney s written tax advice about the tax treatment and consequences of a particular transaction or a tax position that is going to be taken on a tax return. We have acted ascounsel for time warner inc a delaware corporation time warner in connection with the spin off the spin off of time inc a.
A tax opinion letter points to consider. The contractual condition opinion a second common type of tax opinion is a contractual condition opinionthis type of. Opinion simply in the expectation that he will sleep better in the knowledge that an expert has blessed his transaction and given some degree of assurance that the tax consequences will be as expected.
Tax opinion or letter. I will first restate the facts as i know them to confirm their accuracy. Tax opinions provide the client with an opinion and guidance as to how the irs and the courts may treat a particular transaction.
Letterhead of c r a v a t h s w a i n e m o o r e l l p. Practically i write a tax advisory opinion letter much like i would write an appellate brief. Board of director of company xyz address.
For purposes of rendering their opinion ropes gray may rely as to factual matters upon the statements made in this agreement the proxy statement which will be distributed to the shareholders of the acquired fund and other written representations as an officer of the. Form of tax opinion. An effective tax opinion letter will discuss factual details as well as technical concerns.
There is no room for ambiguity and the letter must address each of the elements of the transaction concerned. Newyork office tax opinion regarding the spin off of time inc. In this letter i will provide you with my legal opinion and analysis so you can make a qualified decision regarding the charges you face.
The opinion letters are. The axp corporation will have received the opinion of ropes gray dated as of the closing as to the federal income tax consequences of the reorganization to the acquiring fund and its shareholders. In rendering their opinion.
Sample compilation letter independent accountants compilation report. Next i will provide you with an explanation of the law as it applies in your case and lastly give you my opinion on whether. The firm assumes no obligation to update or modify this opinion letter to reflect any developments that may impact the opinion from and after the date of the opinion letter.
This opinion does not address any federal tax consequences of the transactions set forth herein or transactions related or proximate to such transactions except as set. Management is responsible for the accompanying financial statements of company xyz which comprise the balance sheet income tax basis as of the years ended december 31 20×2 20×1 and 20×0 and the related statements of revenue and expenses income tax basis for the years.