Tax Opinion Policies and Procedures

Hofstra Univ. Legal Studies Research Paper

The Tax Lawyer Vol. 75. No. 3, 2022

46 Pages Posted: 11 May 2022

See all articles by Linda Galler

Linda Galler

Hofstra University - Maurice A. Deane School of Law

Date Written: May 10, 2022

Abstract

This Article summarizes and comments on a 2021 survey by the American College of Tax Counsel (ACTC) on the policies and procedures followed by law and accounting firms in drafting tax opinions. The Article provides back- ground on the contexts in which tax opinions are issued and considerations that are relevant to the composition of such opinions; defines and distinguishes among the levels of assurance at which tax opinions are typically pro- vided; and presents an overview of ethical rules and related considerations, including Circular 230 and the Code’s preparer penalty provisions, implicated in the process of drafting and issuing tax opinions. The Article concludes by making several suggestions to professional firms that are engaged in establishing or reviewing their own opinion processes and to ACTC on how to move forward with its effort to provide useful information and materials to tax professionals.

Suggested Citation

Galler, Linda, Tax Opinion Policies and Procedures (May 10, 2022). Hofstra Univ. Legal Studies Research Paper, The Tax Lawyer Vol. 75. No. 3, 2022, Available at SSRN: https://ssrn.com/abstract=4105841

Linda Galler (Contact Author)

Hofstra University - Maurice A. Deane School of Law ( email )

121 Hofstra University
Hempstead, NY 11549
United States
516-463-5895 (Phone)

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