Sometimes the risk for potential challenge by the Internal Revenue Service (IRS) to the taxability of a proposed transaction, or to the strength of a tax position to be claimed on an income tax return, rises to the level of exposure or complexity so that a tax opinion from competent legal counsel is warranted prior to entering into the transaction.

​

When a legal tax opinion is sought, our highly respected and experienced tax attorneys will analyze your transaction in the context of all applicable legal and tax authorities, and  will opine on the appropriate tax consequences steaming from the transaction. We possess decades of experience in representing taxpayers before the IRS and in opining on the tax treatment of complex domestic and international business transactions, including tax free reorganizations, like-kind exchanges, financing arrangements, controlled foreign corporations (CFCs), transfer pricing, income tax of estates and trusts, income tax treaty implications, permanent establishments, preservation of capital gain characteristics, and consolidated tax return positions.