Tax Opinion Practice & Standards Including Under Circular 230

Over the past half century, the evolution of the tax laws, as well as non-tax laws, has essentially forced tax practitioners to handicap the potential for success of a tax position by the final arbiter (a court) with respect to their written tax advice. This program will discuss the generally accepted benchmark opinion comfort levels for written advice and how they relate to certain legal standards, including with respect to the rules that govern standards of “practice before the IRS,” Circular 230, as well as the rules that govern SEC securities filings.

Topics include:

• Tax Opinion Comfort Levels & Associated Legal Implications
• Tax Advice Standards Under Circular 230 and Requirements for Written Advice
• Tax Opinion Best Practices
• Tax Opinions in SEC Registered Offerings