Tax Opinions

Tax Opinions

If you went to a doctor with a complaint about chest pains, and he told you not to worry because it’s only indigestion, you might want a second opinion. After all, if he’s wrong, you’ve got a great deal to lose, especially if you plan to run a 5K next week. The same logic applies to taxation. If your company is mulling over a development strategy, you need to know if your taxation plan can survive scrutiny from the Internal Revenue Service, or if an alternative tax structure could reduce your exposure further without raising red flags. At Spizzirri Law, tax opinion letters constitute a significant part of our business law practice. Client businesses rely on our analysis when making strategic decisions that depend on favorable tax consequences.

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A mistaken assumption in your company’s tax strategy can destroy the value of a complex transaction. Before you move forward on your development strategy or engage in a tax dispute with the IRS, let Spizzirri Law provide an unbiased opinion of your tax issues.

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We thoroughly examine the details of a proposed transaction, scrutinize the tax plan, and draft a detailed opinion letter, affirming or denying the legal and factual bases for the tax assumptions in the plan. When our letter declares why we, as a disinterested party, believe the corporation’s proposed tax strategy is meretricious, this result sets shareholder minds at ease, and insulates board members from potential allegations they breached their fiduciary duty in approving the transaction. The company can structure the transaction with confidence and will generally find it much easier to raise capital and at a lower cost. Our clients can often secure prior IRS approval that removes any shadow of controversy from the transaction.

On the other hand, when our tax opinion raises red flags about potential conflicts with the U.S. Tax Code, your company now has actionable intelligence to help you rework the deal on a sounder basis.