Sample Tax Opinion Letter

Furthermore, Treasury Regulation §1.1031(k)-1 permits the use of a Qualified Intermediary to facilitate a deferred exchange.

Before analyzing a sample, one must understand the specific language used to define the lawyer’s level of certainty. This is not semantic wordplay; it is the currency of the trade. sample tax opinion letter

This section sets the stage. It typically starts with phrases like, "We have acted as special tax counsel to..." It outlines the engagement scope. More importantly, it defines the facts upon which the opinion is based. This is the "Garbage In, Garbage Out" checkpoint. An opinion is only valid if the underlying facts are true. Furthermore, Treasury Regulation §1

Jones & Associates, Tax Counsel 123 Commerce Drive, Suite 400 Chicago, IL 60601 This section sets the stage

Board of Directors Lender Partners, LLC 123 Finance Way New York, NY 10001

While assumptions cover facts, qualifications cover the law. This section limits the opinion to specific areas of tax law (e.g., Federal Income Tax) and excludes others (e.g., State tax, Payroll tax).