Colvin + Hallett attorneys draw upon their tax expertise to provide opinions to lawyers, accountants, and clients regarding proposed transactions, the tax consequences of business formation and structures, as well as the taxability of payments received upon settlement of lawsuits. Our attorneys have also drawn upon this expertise to serve as expert witnesses in a range of cases involving tax issues.

Tax Advice and Opinions

Colvin + Hallett attorneys provide tax advice and opinions, typically at the request of accountants or lawyers, with respect to the tax consequences of contemplated transactions. Our attorneys have vast experience advising and drafting formal legal opinions, which is informed by our defense of formal opinions in audits, appeals, and litigation. We draw on this experience to meticulously draft opinions able to provide protection from IRS penalties and withstand a challenge. In fact, some of our opinions have been challenged, but to date, none has been defeated.


Advised parties involved in captive insurance arrangements potentially covered by IRS Notice 2016-66 regarding taxpayer and material advisor disclosure obligations, including captive management companies, actuaries, accountants, and lawyers.

Provided opinion regarding whether developers who bought properties and sold them to related LLCs that developed the property were eligible for capital gain treatment.

Offered opinions regarding the proper tax treatment of litigation recoveries and/or lawsuit settlements, including whether damages are included in income or are excludable because they were paid on account of physical personal injury or sickness, and/or whether damages are related to employment or civil rights actions.

Expert Witness

Our attorneys rely upon decades of tax litigation experience, knowledge of IRS practice and procedure, and familiarity with the complexities of the tax code to serve as expert witnesses on tax matters in criminal tax cases and in general civil cases with tax components.


Expert witness in suit between a hedge fund investor and hedge fund involving allegations over the tax consequences; testified for hedge fund, which prevailed in the matter.

Provided expert witness testimony in criminal case on behalf of Atlanta attorney accused of tax crimes; attorney was acquitted.

Served as expert witness for defendant in civil case pursuing damages against tax shelter promoter, which resulted in arbitration verdict for defendant.

Served as expert witness for major financial institution involved in lawsuit regarding multiple SILO/LILO transactions.

Served as expert witness for employee in employment dispute where employee was terminated for raising concerns regarding the employer’s tax reporting; employer settled the case.

Millennium Tower
719 Second Ave., Suite 711
Seattle, WA 98104